Skelley v. Commissioner for Social Security, 3:22-cv-00165-SKB

Plaintiff Justine S. filed for Supplemental Security Income (SSI) on August 23, 2016, alleging disability since March 9, 2009, due to combined physical and mental impairments.
Relevant severe impairments found by the ALJ: fibromyalgia, lumbar degenerative disc disease, diabetes mellitus, COPD, obesity, depression, and history of polysubstance abuse.
At the June 18, 2021 ALJ decision, claimant was found able to perform light work with multiple limitations (e.g., no ladders, limited posturals, no public contact, simple routine tasks, limited changes, no fast-paced/production-quota work).
Treating physician Dr. Carol D. Barlage completed physical and mental medical source statements (Aug. 12, 2020) showing marked limitations (very restricted lifting, sitting/standing/walking, frequent upper-extremity limits, substantial absences, and marked mental limits).
ALJ rejected controlling weight for Dr. Barlage’s opinions, citing inconsistencies with objective findings, conservative treatment, other examining/state consultant opinions, and daily activities; ALJ’s non-disability decision was affirmed by the magistrate judge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ erred by not giving controlling weight to treating physician Dr. Barlage’s opinions	Barlage’s opinions should be controlling because she was a treating physician who documented significant physical and mental limitations	ALJ reasonably discounted Barlage’s opinions for good reasons: lack of objective support, conservative treatment, inconsistencies with Barlage’s own records and other medical evidence, and claimant’s activities	The court held the ALJ gave adequate "good reasons" and substantial evidence supports giving less than controlling weight to Barlage’s opinions; decision affirmed

Bowen v. City of New York, 476 U.S. 467 (1986) (statutory meaning of "disability")
Richardson v. Perales, 402 U.S. 389 (1971) (establishes substantial-evidence standard)
Felisky v. Bowen, 35 F.3d 1027 (6th Cir. 1994) (ALJ decision must be affirmed if supported by substantial evidence even where record could support opposite conclusion)
Blakley v. Commissioner of Social Security, 581 F.3d 399 (6th Cir. 2009) (treating-source opinion factors and "good reasons" requirement)
Gayheart v. Commissioner of Social Security, 710 F.3d 365 (6th Cir. 2013) (ALJ cannot reject treating opinion solely due to non-examining consultants)
Combs v. Commissioner of Social Security, 459 F.3d 640 (6th Cir. 2006) (explains the five-step sequential evaluation process)
Ulman v. Commissioner of Social Security, 693 F.3d 709 (6th Cir. 2012) (courts defer to ALJ when supported by substantial, legitimate evidence)
Warner v. Commissioner of Social Security, 375 F.3d 387 (6th Cir. 2004) (deference to ALJ findings supported by substantial evidence)
Casey v. Secretary of Health and Human Services, 987 F.2d 1230 (6th Cir. 1993) (focus is whether ALJ decision is supported by substantial evidence)
Mullen v. Bowen, 800 F.2d 535 (6th Cir. 1986) (court must uphold Commissioner’s decision if supported by substantial evidence)