Summary
The United States District Court for the Eastern District of Tennessee reviews a final decision of the Commissioner of Social Security denying disability benefits to Tina R. Rickman. The court rejects challenges concerning the evaluation of treating-source opinion evidence, third-party statements, symptoms and non-exertional limitations, and vocational-expert opinions. It holds that substantial evidence supported the agency decision and that any error was harmless, denying relief and affirming the agency decision.
Holdings
- Any error in failing to adopt Dr. White's more restrictive right-hand limitations was harmless because vocational-expert testimony established that Rickman could still perform crossing-guard and usher jobs even with those limitations.
- The ALJ did not commit reversible error by failing to specifically discuss the three vocational-expert opinions because those opinions addressed occupations identified at the earlier hearing and did not address the crossing-guard and usher positions identified at the later hearing.
- Rickman did not establish reversible error in the ALJ's evaluation of her pain, fatigue, knee pain, or hip pain because the argument was inadequately developed and the ALJ sufficiently explained why the knee and hip conditions imposed no RFC limitations.
- The ALJ's decision was supported by substantial evidence and conformed to the relevant legal standards.
Questions Presented
- Whether the ALJ improperly evaluated the treating hand surgeon's opinion and related third-party statements in formulating Rickman's residual functional capacity.
- Whether the ALJ improperly evaluated Rickman's alleged non-exertional limitations and symptoms.
- Whether the ALJ was required to specifically discuss three vocational-expert opinions submitted by Rickman after an earlier administrative hearing.
- Whether any error in the ALJ's treatment of the medical opinion evidence, third-party statements, symptoms, or vocational evidence was harmless.
Disposition
affirmed
Cases Cited (19)
- Blakely v. Comm'r of Soc. Sec., 581 F.3d 399, 405 (6th Cir. 2009)(followed)
- Rogers v. Comm'r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)(followed)
- Cutlip v. Sec'y of Health & Human Servs., 25 F.3d 284, 286 (6th Cir. 1994)(followed)
- Payne v. Comm'r of Soc. Sec., 402 F. App'x 109, 111 (6th Cir. 2010)(followed)
- LeMaster v. Sec'y of Health & Human Servs., 802 F.2d 839, 841 (6th Cir. 1986)(followed)
- Emard v. Comm'r of Soc. Sec., 953 F.3d 844, 849 (6th Cir. 2020)(followed)
- Huizar v. Comm'r of Soc. Sec., 610 F. Supp. 3d 1010, 1015 (E.D. Mich. 2022)(followed)
- Heston v. Comm'r of Soc. Sec., 245 F.3d 528, 535 (6th Cir. 2001)(followed)
- Wright-Hines v. Comm'r of Soc. Sec., 597 F.3d 392, 395 (6th Cir. 2010)(followed)
- Richardson v. Saul, 511 F. Supp. 3d 791, 797 (E.D. Ky. 2021)(followed)
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