Kevin E. v. Commissioner of Social Security

CourtDistrict Court, E.D. Michigan
DecidedJanuary 30, 2026
Docket2:24-cv-13060
StatusUnknown

This text of Kevin E. v. Commissioner of Social Security (Kevin E. 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
Kevin E. v. Commissioner of Social Security, (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

KEVIN E.,

Plaintiff, Case No. 2:24-cv-13060 Honorable Anthony P. Patti v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. _________________________/ OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT (ECF No. 8), GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT (ECF No. 10), and AFFIRMING THE DECISION OF THE COMMISSIONER OF SOCIAL SECURITY

I. Background Kevin E. (“K.E.”) applied for disability insurance (DI) benefits in September / October 2021, alleging disability beginning September 1, 2021 (i.e., the alleged onset date (AOD)), at which point he was 61 years old, i.e., a person of advanced age who is closely approaching retirement age, 20 C.F.R. § 404.1563(e). (ECF No. 5, PageID.356-359.) Plaintiff’s claims were denied initially in February 2022 and upon reconsideration in September 2022. (Id., PageID.208-231, 260-269, 271- 280.) K.E. sought a hearing with an administrative law judge (ALJ) (id., PageID.281), and, on September 29, 2023, ALJ Lauren Burstein conducted a hearing, at which the claimant, his counsel, and a vocational expert (VE) appeared (id., PageID.180-206). On October 4, 2023, ALJ Burstein issued an unfavorable

decision. (Id., PageID.232-253.) K.E. requested review (id., PageID.343-346); however, on September 20, 2024, the Appeals Council (AC) denied the request for review (id., PageID.21-

26).1 II. Instant Case & Pending Motion

On November 19, 2024, Plaintiff brought this action under 42 U.S.C. § 405(g) for review of the final decision of the Commissioner of Social Security (“Commissioner”). The parties have consented to my jurisdiction to handle this case through entry of a final judgment. (ECF No. 3.) Currently before the Court is Plaintiff’s motion for summary judgment (ECF

No. 8), which challenges the ALJ’s treatment of the opinion evidence and the subjective symptom testimony. (Id., PageID.1663-1671.) The Commissioner filed a cross-motion for summary judgment (ECF No. 10), and Plaintiff has filed a reply (ECF No. 11).

1 ALJ Burstein had multiple medical records before her at the time of her decision. (See ECF No. 5, PageID.250-253; id., PageID.491-1646 [Exhibits 1F-35F].) The administrative record also contains medical records for a July 21, 2023 to July 23, 2023 hospital admission (see id., PageID.32-175), although it seems these records may just have been available to the Appeals Council. On January 28, 2026, the Court conducted a remote hearing, at which Attorney Cheryl O’Brien and Assistant United States Attorney Lisa G. Smoller

appeared. After a brief recess, the Court issued its opinion and reasoning from the bench, all of which is incorporated by this reference as though fully restated herein. III. Standard

Plaintiff has the burden of proof on his statements of error, as he challenges the ALJ’s treatment of the opinion evidence and Plaintiff’s subjective testimony, each of which occurred between steps 3 and 4 of the sequential process. Walters v. Comm’r of Soc. Sec., 127 F.3d 525, 529 (6th Cir. 1997) (“[D]uring the first four

steps, the claimant has the burden of proof; this burden shifts to the Commissioner only at Step Five.”). “[A] decision supported by substantial evidence must stand, even if [the court] might decide the question differently based on the same

evidence.” Biestek v. Comm’r of Soc. Sec., 880 F.3d 778, 783 (6th Cir. 2017). The Court must “‘take into account whatever in the record fairly detracts from [the] weight’” of the Commissioner’s decision. TNS, Inc. v. NLRB, 296 F.3d 384, 395 (6th Cir. 2002) (quoting Universal Camera Corp. v. NLRB, 340 U.S. 474, 487

(1951)). Even if the ALJ’s decision meets the substantial evidence standard, “‘a decision of the Commissioner will not be upheld where the SSA fails to follow its own regulations and where that error prejudices a claimant on the merits or

deprives the claimant of a substantial right.’” Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009) (quoting Bowen v. Comm’r of Soc. Sec., 478 F.3d 742, 746 (6th Cir. 2007)).

IV. Discussion Before proceeding to Plaintiff’s specific statements of error, the Court notes the ALJ’s related RFC determination:

. . . [Plaintiff] has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) [i.e., exertional limitations] except he can never kneel, crawl, or climb ladders, ropes, or scaffolds. He can occasionally climb ramps and stairs, stoop, and crouch [i.e., postural limitations]. He can reach overhead occasionally with the right upper extremity [i.e., manipulative limitations] but cannot perform overhead lifting. He must avoid unprotected heights and avoid slippery, dangerous, or uneven terrain [i.e., environmental limitations].

(ECF No. 5, PageID.239-245.) A. Opinion evidence (20 C.F.R. § 404.1520c) Plaintiff argues that the ALJ failed to properly evaluate the opinion evidence. (ECF No. 8, PageID.1663-1669; see also ECF No. 11, PageID.1699- 1700.) The ALJ found the state agency medical consultants’ opinions (see ECF No. 5, PageID.208-218; id., PageID.221-231) “partially persuasive,” treating physician Maatha Alani, M.D.’s opinion (see id., PageID.783-786) “unpersuasive” or “less persuasive,” Dr. Miguel Granados’s opinion (see id., PageID.788-789) “partially persuasive,” and consultative examiner Bina Shaw, M.D.’s opinion (see id., PageID.1011-1023) “minimally persuasive” in part and “unpersuasive” in part. (Id., PageID.243-244.)

1. Treating physician Dr. Alani Plaintiff specifically challenges the ALJ’s treatment of Dr. Alani’s MSS. (ECF No. 8, PageID.1664-1665.) The ALJ explained in her written decision that

“Dr. Alani failed to offer any objective support for his conclusion, which renders his opinion less persuasive[,]” “this opinion is inconsistent with Dr. Alani’s June and August 2021 treatment notes, which indicates normal gait, coordination, motor function, cervical and musculoskeletal range of motion, reflexes, and sensation[,]”

and the opinion “is likewise unsupported by the claimant’s September 2021 orthopedic findings of normal posture and paraspinal muscle tone.” (ECF No. 5, PageID.244.) The ALJ then explained: “I find the claimant’s display of antalgic

gait, mild muscle spasms, and slightly decreased left lower extremity strength, coupled with findings of lumbar degenerative disc disease and right shoulder arthritic spurring, supports limitation to reduced light exertion with no crawling or climbing ladders, ropes, or scaffolds; occasional stooping, crouching, climbing

ramps and stairs, and overhead reaching; and no overhead lifting[,]” (id.), in support of which she generally cited multiple records, albeit without attribution. (See id. (citing id., PageID.559-560, 565, 705, 719, 729, 753-755).) Preliminarily, the Court acknowledges Plaintiff’s supportability argument that Dr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Kevin E. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kevin-e-v-commissioner-of-social-security-mied-2026.