Hawraa A. v. Commissioner of Social Security

CourtDistrict Court, E.D. Michigan
DecidedJanuary 29, 2026
Docket2:25-cv-10763
StatusUnknown

This text of Hawraa A. v. Commissioner of Social Security (Hawraa A. v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hawraa A. v. Commissioner of Social Security, (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

HAWRAA A., Case No. 25-cv-10763 Plaintiff, Magistrate Judge Elizabeth A. Stafford v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT (ECF NOS. 12, 14)

I. Introduction and Background Plaintiff Hawraa A. 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(c) and move for summary judgment. ECF No. 8; ECF No. 12; ECF No. 14. Plaintiff received child disability benefits, which were discontinued in May 2018 during a continuing disability review. ECF No. 7-1, PageID.586. She applied for SSI in December 2020. Id., PageID.592. In a November 2022 decision, an ALJ found plaintiff not disabled under the childhood

disability standard. Id., PageID.46-61. The Appeals Council denied review. Id., PageID.29-31. Plaintiff appealed to this Court, and the parties stipulated to remand the case. Id., PageID.727-732. Another ALJ held a

hearing in January 2025, after plaintiff had turned 18 in April 2024. Id., PagelD.586. In the decision that followed, the ALJ found plaintiff not disabled under both the childhood and adult standards of disability. Id., PageID.586-603. Plaintiff appeals that decision. ECF No. 1.

After review of the record, the Court GRANTS plaintiff’s motion for summary judgment (ECF No. 12); DENIES the Commissioner’s motion for summary judgment (ECF No. 14); and REMANDS the ALJ’s decision under

sentence four of 42 U.S.C. § 405(g). 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, 139 S. Ct. 1148, 1154 (2019) (internal quotation marks omitted). 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.”). B.

Plaintiff contends that the ALJ’s “sparse” RFC analysis under the adult standard of disability is deficient. ECF No. 12, PageID.1493-1496. She maintains that the ALJ provided no explanation for discounting

plaintiff’s self-described limitations and instead determined the RFC based on her interpretation of raw medical data. Id. The Court agrees that the ALJ failed to provide a logical bridge between the evidence and the RFC.

The ALJ found that plaintiff had the RFC to perform light work,1 except: the claimant can occasionally climb ramps and stairs, but never ladders, ropes and scaffolds. The claimant can occasionally stoop, kneel, crouch, and crawl. The claimant can occasionally overhead reach. The claimant can have no exposure to unprotected heights or dangerous moving machinery. The claimant is limited to occasional interaction with coworkers, supervisors and the general public. ECF No. 7-1, PageID.601. The ALJ noted that the record contains little medical evidence after plaintiff turned 18 in April 2024, as plaintiff lost her health insurance coverage. Id., PageID.598, 601, 654. But the ALJ discussed plaintiff’s hearing testimony and available medical evidence in other sections the decision.2 Id., PageID.596-600. The ALJ concluded that

1 Light work is defined as “lifting no more than 20 pounds at a time with frequent lifting or carrying of objects weighing up to 10 pounds….[A] job is in this category when it requires a good deal of walking or standing…[and] when it involves sitting most of the time but with some pushing and pulling of arm-hand or leg-foot controls.” 20 C.F.R. § 416.967(b); Social Security Ruling (SSR) 83-10, 1983 WL 31251 (1983). 2 Although plaintiff is correct that the ALJ did not summarize her 2025 hearing testimony in the section of the decision applying the adult disability standard, the ALJ did summarize it when applying the childhood disability standard. See ECF No. 7-1, PageID.596-597; ECF No. 12, PageID.1494. A court must read an ALJ’s RFC analysis in the context of the entire decision and may consider analysis in other sections when evaluating the plaintiff’s reported limitations conflicted with the record, reasoning that plaintiff reported doing well at a May 2024 medical visit and that her pain

was treated conservatively. Id., PageID.597, 601. Given the conservative treatment history, lack of objective findings, and plaintiff’s activities of daily living, the ALJ assessed the above RFC. Id.

Because the ALJ “is charged with the responsibility” of determining the RFC, she need not base her RFC findings on a physician’s opinion. See Mokbel-Aljahmi v. Comm’r of Soc. Sec., 732 F. App’x 395, 401 (6th Cir. 2018) (cleaned up). Still, an ALJ’s decision must “provide an accurate

and logical bridge between the evidence” and the RFC. Gross v. Comm’r of Soc. Sec., 247 F. Supp. 3d 824, 829 (E.D. Mich. 2017) (cleaned up); see also Tucker v. Comm’r of Soc. Sec., 775 F. App’x 220, 226 (6th Cir. 2019)

(“No bright-line rule exists in our circuit directing that medical opinions must be the building blocks of the [RFC] finding, but the [ALJ] must make a connection between the evidence relied on and the conclusion reached.”). That is, the “ALJ must articulate, at some minimum level, his analysis of the

evidence to allow the appellate court to trace the path of his reasoning” to permit meaningful review. Cortes v. Comm’r of Soc. Sec., No. 18-13347,

RFC. Smith-Johnson v. Comm’r of Soc. Sec., 579 F. App’x 426, 435 n.9 (6th Cir. 2014); Bledsoe v. Barnhart, 165 F. App’x 408, 411 (6th Cir. 2006). 2020 WL 2812761, at *10 (E.D. Mich. May 29, 2020) (cleaned up). An ALJ’s failure to provide an adequate rationale warrants remand, even if

substantial evidence supports the RFC. Gross, 247 F. Supp. 3d at 829. The ALJ’s RFC analysis offers no explanation tying the evidence to the functional limitations assessed.

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Related

Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
Kimberly Smith-Johnson v. Comm'r of Social Security
579 F. App'x 426 (Sixth Circuit, 2014)
Bledsoe v. Barnhart
165 F. App'x 408 (Sixth Circuit, 2006)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Gross v. Commissioner of Social Security
247 F. Supp. 3d 824 (E.D. Michigan, 2017)
Hatmaker v. Commissioner of Social Security
965 F. Supp. 2d 917 (E.D. Tennessee, 2013)

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Bluebook (online)
Hawraa A. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hawraa-a-v-commissioner-of-social-security-mied-2026.