Watkins v. Commissioner of Social Security
3:24-cv-01570
N.D. OhioApr 14, 2025Background
- Noelle E. Watkins applied for Social Security Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI), alleging disability due to mental health conditions from August 7, 2021.
- Watkins was 22 at onset, with a high school education, no past relevant work, and claimed impairments including bipolar disorder, generalized anxiety disorder, ADHD, and borderline personality disorder.
- Her applications were initially denied and denied again upon reconsideration; she requested a hearing before an ALJ.
- The ALJ found that Watkins had severe impairments but retained the residual functional capacity (RFC) to perform simple, repetitive work with non-exertional social and pace limitations.
- The ALJ denied benefits, the Appeals Council affirmed, and Watkins sought judicial review, challenging the RFC determination and evaluation of medical evidence/opinions and her subjective complaints.
- Magistrate Judge issued a Report and Recommendation upholding the ALJ’s decision, finding it supported by substantial evidence and proper legal standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's evaluation of medical opinions | ALJ failed to properly assess counselor Bower’s opinion on supportability and consistency factors | ALJ properly considered supportability and consistency; explained reasons for finding opinion only "somewhat persuasive" | ALJ properly evaluated opinion as required under regulations |
| Evaluation of subjective symptom allegations | ALJ misunderstood (or over-relied on) daily activities and medical provider interactions in assessing functional limitations | ALJ considered all appropriate factors including activities, medical evidence, and non-compliance history | ALJ’s evaluation was appropriate and supported by evidence |
| Whether substantial evidence supports RFC finding | ALJ did not identify substantial evidence for RFC and "strategically omitted" supporting evidence | ALJ considered the entire record, including objective and subjective factors | Substantial evidence supports ALJ’s RFC determination |
| Consideration of pre-onset evidence | ALJ failed to consider pre-June 2022 evidence relevant to onset and work attempts | ALJ considered the whole record, including pre-onset and post-onset evidence | ALJ’s record review was adequate for RFC and conclusions |
Key Cases Cited
- Rogers v. Comm'r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (articulates standard for substantial evidence review of SSA decisions)
- Jones v. Comm'r of Soc. Sec., 336 F.3d 469 (6th Cir. 2003) (substantial evidence supports ALJ if supported by some relevant evidence)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (defines "substantial evidence" for purposes of SSA appeals)
- Blakley v. Comm'r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (court affirms if substantial evidence supports ALJ, even if record could support a different outcome)
- Poe v. Comm'r of Soc. Sec., [citation="342 F. App'x 149"] (6th Cir. 2009) (ALJ not required to adopt medical opinion verbatim in RFC)