Kristin J. v. Commissioner of Social Security

CourtDistrict Court, E.D. Michigan
DecidedJanuary 15, 2026
Docket2:24-cv-12814
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

KRISTIN J., Case No. 24-cv-12814 Plaintiff, Magistrate Judge Elizabeth A. Stafford v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT (ECF NOS. 8, 10)

I. Introduction Plaintiff Kristin J. appeals the final decision of defendant Commissioner of Social Security (Commissioner) to deny her application for disability insurance benefits (DIB) under the Social Security Act. Both parties consented to the undersigned conducting all proceedings under 28 U.S.C. § 636(c) and moved for summary judgment. ECF No. 4; ECF No. 8; ECF No. 10. After a hearing below, an administrative law judge (ALJ) found: 1. Plaintiff had the severe impairments of “generalized anxiety disorder and vertiginous syndromes and other disorders of the vestibular system.” ECF No. 5-1, PageID.37.

2. Plaintiff had no impairments that met or medically equaled a listed impairment. Id., PageID.38-19.

3. Plaintiff had the residual functional capacity (RFC) “to perform a full range of work at all exertional levels,” while avoiding “concentrated exposure to hazards such as unprotected heights, uneven planes, and hazardous equipment.” Id., PageID.39-40. She could also understand, remember, and carry out simple, routine, repetitive tasks. Id.

Under § 405(g), this Court’s review is limited to determining whether the Commissioner’s decision is supported by substantial evidence1 and conformed 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

1 Only the evidence in the record below may be considered when determining whether the ALJ’s decision is supported by substantial evidence. Bass v. McMahon, 499 F.3d 506, 513 (6th Cir. 2007). 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.”).

Under these standards, the Court affirms the Commissioner’s decision. II. Analysis

Plaintiff first argues that the RFC assessed by the ALJ did not reflect the severity of her impairments, “particularly her cognitive and concentration deficits.” ECF No. 8, PageID.1731-1735. She claims that the ALJ failed to “review all limitations founded in substantial evidence” and

she “challenges the accuracy of the ALJ’s review of the record.” Id., PageID.1733. In support of her argument, plaintiff cites hundreds of pages of medical records that she claims support her argument that the assessed RFC was insufficient. Id., PageID.1733-1734, (citing ECF No. 5-1, PageID.700-762, 930-1322, 1347-1356, 1696-1705).

In citing hundreds of records that plaintiff alleges support a more restrictive RFC, she invites the Court to reweigh the evidence. As noted, this Court cannot independently weigh the evidence even if the evidence

she cites may support a different conclusion. Hatmaker, 965 F. Supp. 2d at 930. Rather, “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.” Biestek, 587

U.S. at 102-03. And plaintiff bears the burden of showing that, under the existing record, she needs a more restrictive RFC. Jordan v. Comm’r of Soc. Sec.,

548 F.3d 417, 423 (6th Cir. 2008). The Court has no duty to scour the record on her behalf. “Judges are not like pigs, hunting for truffles that might be buried in the record.” Knight Capital Partners Corp. v. Henkel AG & Co., KGaA, 930 F.3d 775, 780 n.1 (6th Cir. 2019) (cleaned up); see also

Justice v. Comm’r of Soc. Sec., No. 21-CV-10503, 2022 WL 16709719, at *7 (E.D. Mich. July 11, 2022), adopted, 2022 WL 12419673 (E.D. Mich. Oct. 21, 2022) (“Justice cites no evidence in the record explaining the impact these conditions have on her functioning—and the Court has no duty to search for evidence to support her claims.”).

Plaintiff’s claim that she needed a more restrictive RFC fails also because she “does not specify any additional work-related functional limitations the ALJ should have, but did not, include in the RFC assessment

resulting from” her alleged impairments. Huizar v. Comm’r of Soc. Sec., 610 F. Supp. 3d 1010, 1016 (E.D. Mich. 2022) (cleaned up). Plaintiff next claims the ALJ erred in his evaluation of her subjective symptoms. ECF No. 8, PageID.1735-1736. 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. 20 C.F.R. § 404.1529(a); Social Security Ruling (SSR) 16-3p. If so, the ALJ assesses any work-related limitations by determining the intensity, persistence, and limiting effects of these symptoms. 20 C.F.R. § 404.1529(a); SSR 16-3p. In sum, ALJs assess

whether the symptoms claimed 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. § 404.1529(a). Although a plaintiff’s description of his symptoms will “not

alone establish that [he] 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

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Related

Jordan v. Commissioner of Social Security
548 F.3d 417 (Sixth Circuit, 2008)
Bass v. McMahon
499 F.3d 506 (Sixth Circuit, 2007)
Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Knight Capital Partners Corp. v. Henkel AG & Co.
930 F.3d 775 (Sixth Circuit, 2019)
Roby v. Commissioner of Social Security
48 F. App'x 532 (Sixth Circuit, 2002)
Hatmaker v. Commissioner of Social Security
965 F. Supp. 2d 917 (E.D. Tennessee, 2013)

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