Tina Smalley v. Comm'r of Soc. Sec., 20-1865

Smalley injured her lower back in a 2012 car accident and stopped working as a resident care manager on May 5, 2015; she filed for SSDI on Nov. 16, 2015.
ALJ found severe impairments: lumbar degenerative disc disease, depression, anxiety, and PTSD, and assessed an RFC for a limited range of light work with nonexertional restrictions.
Treating physician Dr. Marie‑Louise Sagan‑Yewah opined Smalley could not sit or stand for more than 1–2 hours, needed near‑hourly unscheduled breaks, could not bend, couldn’t lift over 20 pounds, and would miss ~3 days/month.
The ALJ assigned the treating opinion “little weight,” citing (generally) lack of support in the records and notes of normal gait and station, and relied on a state‑agency reviewer to support the RFC.
The district court agreed the ALJ failed to give adequate “good reasons” for discounting the treating opinion but deemed the error harmless and affirmed.
The Sixth Circuit vacated and remanded, holding the ALJ’s reasons were insufficient and the error was not harmless because the ALJ did not explain how specific evidence undermined the treating physician’s work‑preclusive limitations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ violated the treating‑physician rule / "good reasons" requirement by discounting treating physician's opinion	ALJ failed to give sufficiently specific reasons for giving the treating opinion little weight and did not address key limitations (sitting/standing, hourly breaks, absences)	ALJ pointed to records (normal gait/station, imaging showing mild findings, ambulatory status) and reserved disability determination to Commissioner	ALJ violated the rule: reasons were conclusory and did not show how the record undermined the treating physician’s opinion
Whether the procedural error was harmless	Error prejudiced Smalley because ALJ did not explain why treating opinion’s work‑preclusive limits were rejected; those limits could affect disability outcome	Error was harmless because substantial evidence (state reviewer, objective tests, normal gait) supports RFC and outcome	Not harmless: court could not discern how specific evidence refuted treating physician’s limitations; remand required

Wilson v. Comm'r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (establishes treating‑physician rule and "good reasons" requirement)
Rogers v. Comm'r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (treating sources generally entitled to greater weight; need for specific reasons)
Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (explaining "substantial evidence" standard)
Hensley v. Astrue, 573 F.3d 263 (6th Cir. 2009) (remand appropriate where ALJ fails to provide good reasons)
Hargett v. Comm'r of Soc. Sec., 964 F.3d 546 (6th Cir. 2020) (ALJ must identify and explain inconsistencies when discounting treating opinion)
Hernandez v. Comm'r of Soc. Sec., [citation="644 F. App'x 468"] (6th Cir. 2016) (discussing when indirect references may satisfy good‑reasons goal)
Hall v. Comm'r of Soc. Sec., [citation="148 F. App'x 456"] (6th Cir. 2005) (remand where ALJ’s basis for rejecting treating restrictions unclear)
Friend v. Comm'r of Soc. Sec., [citation="375 F. App'x 543"] (6th Cir. 2010) (requiring clarity on why treating opinion was rejected)
Cole v. Astrue, 661 F.3d 931 (6th Cir. 2011) (good‑reasons rule protects substantial rights and aids appellate review)