Barbara C. v. Commissioner of Social Security

District Court, E.D. Michigan·Decided April 29, 2026·No. 2:25-cv-11522·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

BARBARA C., Case No. 25-cv-11522 Plaintiff, Magistrate Judge Elizabeth A. Stafford v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER ON CROSS MOTIONS FOR SUMMARY JUDGMENT (ECF NOS. 10 & 12)

I. Introduction

Plaintiff Barbara C. appeals the final decision of defendant Commissioner of Social Security (Commissioner), which denied her application for supplemental security income (SSI) under the Social Security Act. Both parties consented to the undersigned conducting all proceedings under 28 U.S.C. § 636(b) and moved for summary judgment. ECF No. 8; ECF No. 10; ECF No. 12. After a hearing below, an administrative law judge (ALJ) found: 1. Plaintiff had the severe impairments of “degenerative disc disease of the cervical spine; peripheral neuropathy; asthma; chronic obstructive pulmonary disease; emphysema, epilepsy; migraine headaches; depression; anxiety; posttraumatic stress disorder; and cannabis use disorder.” ECF No. 7-1, PageID.37.

2. Plaintiff had no impairments that met or medically equaled a listed impairment. Id., PageID.37-38.

3. Plaintiff had the residual functional capacity (RFC) to perform light work “except she can only occasionally reach overhead with her right upper extremity. The claimant can only frequently, as opposed to continuously, balance, crouch, and kneel; only occasionally stoop, crawl, and climb stairs; and never climb ladders. Furthermore, the claimant must avoid concentrated exposure to extreme cold, extreme heat, humidity, wetness, fumes, odors, dusts, gases, and vibration. The claimant must also avoid all exposure to hazards such as dangerous moving machinery and unprotected heights. Additionally, the claimant is limited to performing simple, routine, repetitive tasks in jobs with few, if any, changes in the work setting and no production rate pace work.” Id., PageID.41.

Relying on the testimony from a vocational expert, the ALJ found that jobs existed in the national economy that plaintiff could perform, and that plaintiff was not disabled. Id., PageID.53-54. II. Analysis

A. Under § 405(g), this Court’s review is limited to determining whether the Commissioner’s decision is supported by substantial evidence and was made in conformity with proper legal standards. Gentry v. Comm’r of Soc. Sec., 741 F.3d 708, 722 (6th Cir. 2014). Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficient evidence to support the agency’s factual determinations. And whatever the meaning of substantial in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is more than a mere scintilla. It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

Biestek v. Berryhill, 587 U.S. 97, 102-03 (2019) (cleaned up). The substantial-evidence standard does not permit the Court to independently weigh the evidence. Hatmaker v. Comm’r of Soc. Sec., 965 F. Supp. 2d 917, 930 (E.D. Tenn. 2013) (“The Court may not reweigh the evidence and substitute its own judgment for that of the Commissioner merely because substantial evidence exists in the record to support a different conclusion.”); see also Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284, 286 (6th Cir. 1994) (“If the Secretary’s decision is supported by substantial evidence, it must be affirmed even if the reviewing court would decide the matter differently, and even if substantial evidence also supports the opposite conclusion.”). Plaintiff argues that the ALJ failed to properly evaluate both her allegations of pain and physical dysfunction, as well as the opinion of state agency psychological consultant Edward Czarnecki, Ph.D. ECF No. 10, PageID.1338, 1342-1354; ECF No. 13, PageID.1378-1382. The Court disagrees and affirms the ALJ’s decision.

B.

Plaintiff claims that the ALJ failed to properly evaluate her subjective symptoms of pain and difficulty walking, citing her hearing testimony that she could not walk for more than 15 to 20 minutes. ECF No. 10, PageID.1343-1348. An ALJ’s subjective symptom evaluation should not be disturbed “absent compelling reasons.” Smith v. Halter, 307 F.3d 377, 379 (6th Cir.

2001).1 The regulations set forth a two-step process for evaluating a plaintiff’s subjective symptoms. First, the ALJ evaluates whether objective medical evidence of an underlying condition exists and whether that

condition could reasonably be expected to produce the alleged symptoms.

1 SSR 16-3p eliminated use of the term “credibility” from official policy and clarifies that a “subjective symptom evaluation is not an examination of an individual's character.” Rhinebolt v. Comm’r of Soc. Sec., No. 2:17-CV- 369, 2017 WL 5712564, at *8 (S.D. Ohio Nov. 28, 2017), adopted, 2018 WL 494523 (S.D. Ohio Jan. 22, 2018). Despite the linguistic clarification, courts continue to rely on pre-SSR 16-3p authority providing that the ALJ’s credibility determinations are given great weight. See, e.g., Kilburn v. Comm’r of Soc. Sec., No. 1:17-CV-603, 2018 WL 4693951, at *7 (S.D. Ohio Sept. 29, 2018); Duty v. Comm’r of Soc. Sec., No. 2:17-CV-445, 2018 WL 4442595, at *6 (S.D. Ohio Sept. 18, 2018). 20 C.F.R. § 416.929(a); Social Security Ruling (SSR) 16-3p. If so, the ALJ addresses any work-related limitations by determining the intensity,

persistence, and limited effects of these symptoms. 20 C.F.R. § 416.929(a); SSR 16-3p. In sum, ALJs assess whether the symptom claims are “consistent with the objective medical and other evidence in the

individual’s record.” SSR 16-3p. To evaluate the limiting effects of subjective symptoms, ALJs consider all available evidence, including the plaintiff’s history, laboratory findings, statements by the plaintiff, and medical opinions. 20 C.F.R.

§ 416.929(a). Although a plaintiff’s description of her symptoms will “not alone establish that [she] is disabled,” id., the ALJ may not disregard the plaintiff’s subjective complaints because they lack substantiating objective

evidence. SSR 16-3p. Along with objective evidence, ALJs must consider a plaintiff’s daily activities; the location, duration, frequency, and intensity of pain; precipitating and aggravating factors; the type, dosage, and side effects of medication to alleviate symptoms; and any other treatment or

measures used to relieve pain. 20 C.F.R. § 416.929(c)(3). The ALJ accurately summarized plaintiff’s subjective reports that she had trouble walking. For example, he noted that in June 2022 plaintiff

reported having experienced “weakness in her legs when walking over the previous few weeks.” ECF No. 7-1, PageID.42. The ALJ cited several medical records describing plaintiff as having a “slow gait.” Id., PageID.43-

45.

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Barbara C. v. Commissioner of Social Security, (E.D. Mich. 2026).

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