Tracy Lynne Taylor v. Commissioner of Social Security

District Court, E.D. Michigan·Decided March 30, 2026·No. 2:25-cv-10068·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

TRACY LYNNE TAYLOR,

Plaintiff, Case No. 25-cv-10068 Hon. Jonathan J.C. Grey v. Magistrate Judge Patricia Morris COMMISSIONER OF SOCIAL SECURITY,

Defendant. _____________________________/

ORDER ADOPTING REPORT AND RECOMMENDATION (ECF No. 16), OVERRULING PLAINTIFF’S OBJECTIONS TO THE REPORT AND RECOMMENDATION (ECF No. 17), GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT (ECF No. 14), AND DENYING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT (ECF No. 12)

I. INTRODUCTION This matter is before the Court on Plaintiff Tracy Lynne Taylor’s (“Taylor”) and Defendant Commissioner of Social Security’s (“the Commissioner”) cross-motions for summary judgment. (ECF Nos. 12, 14.) On November 10, 2025, Magistrate Judge Patricia T. Morris issued a Report and Recommendation (the “R&R”) (ECF No. 16) in which she recommends that the Court: (i) deny Taylor’s motion for summary judgment (ECF No. 12), (ii) grant the Commissioner’s motion for summary judgment (ECF No. 14), and (iii) affirm the final decision of the Administrative Law Judge (ALJ). Taylor filed two objections to the R&R,

to which the Commissioner responded. (ECF Nos. 17, 18.) For the reasons set forth below, the Court OVERRULES Taylor’s objections, ADOPTS Magistrate Judge Morris’ R&R in its entirety,

GRANTS the Commissioner’s motion for summary judgment, and DENIES Taylor’s motion for summary judgment.

II. LEGAL STANDARD A. De Novo Review Pursuant to Federal Rule of Civil Procedure 72(b)(3), “[t]he district

judge must determine de novo any part of the magistrate judge’s disposition that has been properly objected to. The district judge may accept, reject, or modify the recommended disposition; receive further

evidence; or return the matter to the magistrate judge with instructions.” B. Substantial Evidence Standard The Court “must affirm the [ALJ’s] conclusions absent a

determination that the Commissioner has failed to apply the correct legal standards or has made findings of fact unsupported by substantial evidence in the record.” Sullivan v. Comm’r of Soc. Sec., 595 F. App’x 502, 506 (6th Cir. 2014) (quoting Walters v. Comm’r of Soc. Sec., 127 F.3d 525, 528 (6th Cir. 1997)). “Substantial evidence is more than a scintilla of

evidence but less than a preponderance; it is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. (quoting Cutlip v. Sec’y of Health & Human Servs., 25 F.3d 284, 286 (6th

Cir. 1994)). “[T]he threshold for such evidentiary sufficiency is not high.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). Ultimately, if “the [ALJ’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.” Cutlip, 25

F.3d at 286 (citations omitted). III. ANALYSIS A. First Objection

Taylor first argues that “[t]he Court should decline to adopt the Magistrate Judge’s interpretation and/or application of SSR 83-14.” (ECF No. 17, PageID.484.)

SSR 83-14 “provide[s] a framework for decisions concerning persons who have both a severe exertional impairment and a nonexertional limitation or restriction.” 1983 WL 31254, at *1 (Jan. 1, 1983) (emphasis added). According to the ALJ’s decision, while Taylor has certain nonexertional limitations, she “has the residual functional

capacity [‘RFC’] to perform a full range of work at all exertional levels.” (ECF No. 9-1, PageID.89) (emphasis added). Because Taylor does not have a severe exertional impairment, Magistrate Judge Morris declined

to apply SSR 83-14 and instead cited SSR 85-15, which provides “a framework for evaluating solely nonexertional impairments.” 1985 WL

56857, at *1 (Jan. 1, 1985). Taylor contends that, because she has “(i) a severe impairment and (ii) a non-exertional limitation or restriction,” Magistrate Judge Morris

should have applied SSR 83-14, which would have required the ALJ “to consider whether [Taylor’s] occupational base [was] significantly diminished for light (and greater-exertion) work.” (ECF No. 17,

PageID.484–485 (citing SSR 83-14, 1983 WL 31254, at *5.).) The Court disagrees. As correctly noted in the R&R, SSR 83-14 applies to individuals with both a severe exertional impairment and a nonexertional

limitation. Taylor does not have a severe exertional impairment, thus Magistrate Judge Morris correctly deemed SSR 83-14 inapplicable. The Court notes that, despite framing her objection as an interpretive challenge to SSR 83-14, Taylor seemingly includes two

additional sub-arguments within her first objection. She contends that the ALJ: (i) “did not offer any statement as to how [Taylor’s] monocular vision affected [her] acuity, accommodation, or depth perception as would

be relevant to an RFC” and instead “simply noted certain raw visual acuity measures related to the left eye,” and (ii) “did not provide the

function-by-function assessment necessary to determine” how “a person who has [Taylor’s] conditions is functionally impacted by these raw acuity measures.” (ECF No. 17, PageID.485–486.)

As to the first argument, the Commissioner appropriately notes that it rehashes, nearly word for word, an argument previously raised in Taylor’s motion for summary judgment. (See ECF No. 12, PageID.437–

438.) This Court is not obligated to address objections made in this form because the objections fail to identify the specific errors in the magistrate judge’s proposed recommendations, see, e.g., Camardo v. Gen. Motors Hourly–Rate Emps. Pension Plan, 806 F. Supp. 380, 382 (W.D.N.Y.1992) (recitations of nearly identical arguments are insufficient as objections and constitute an improper “second bite at the apple”), and such objections undermine the purpose of the Federal Magistrate’s Act, 28 U.S.C. § 636, which serves to reduce duplicative work and conserve judicial resources, see, e.g., Howard v. Sec’y of Health & Human Servs., 932 F.2d 505, 509 (6th Cir.1991). See also Nickelson v. Warden, No. 1:11-cv-334, 2012 WL 700827, at *4 (S.D. Ohio Mar. 1, 2012) (“[O]bjections to magistrate judges’ reports and recommendations are not meant to be simply a vehicle to rehash arguments set forth in the petition.”).

Owens v. Comm’r of Soc. Sec., No. 1:12-CV-47, 2013 WL 1304470, at *3 (W.D. Mich. Mar. 28, 2013). Magistrate Judge Morris thoroughly addressed Taylor’s argument in the R&R (see ECF No. 16, PageID.476–480) and, beyond objecting to Magistrate Judge Morris’ application of SSR 83-14, which the Court addressed above, Taylor has not identified any other purported

deficiencies in Magistrate Judge Morris’ analysis. The Court agrees with the analysis set forth in the R&R and thus refrains from addressing Taylor’s repetitive argument.

Taylor’s second argument, that the ALJ did not provide the necessary function-by-function assessment, is equally unpersuasive. As the Commissioner correctly notes, “[a]lthough a function-by-function

analysis is desirable, SSR 96-8p does not require ALJs to produce such a detailed statement in writing.” Delgado v. Comm’r of Soc.

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