Justina Hurst o/b/o G.J.D.A. v. Commissioner of Social Security

Hurst · United States District Court for the Northern District of Ohio, Eastern Division · February 9, 2026 · No. 5:25-cv-1244

Summary

This Report and Recommendation concerns judicial review of the Commissioner of Social Security’s denial of supplemental security income benefits to a minor claimant. The magistrate judge recommends affirming the Commissioner’s decision, concluding that the ALJ properly evaluated the consultative examiner’s opinion and that the claimant’s impairments did not meet, medically equal, or functionally equal a listed impairment.

Holdings

  1. The ALJ satisfied the regulatory articulation requirement because, although he did not use the words "supportability" and "consistency," he discussed the opinion's examination findings and subjective reports and compared them with treatment notes, school records, and other evidence.
  2. The ALJ was not required to discuss opinion evidence in a particular order or in a separate section; the decision may be evaluated as a whole.

Questions Presented

  1. Whether the ALJ adequately articulated consideration of the supportability and consistency factors when evaluating Dr. Johnson-Brown's consultative medical opinion.
  2. Whether the ALJ was required to discuss the medical-opinion evidence in a particular order or in a separate section of the decision.

Disposition

other

Cases Cited (17)

  • McClanahan v. Commissioner of Social Security, 193 F. App'x 422, 425 (6th Cir. 2006)(followed)
  • Smoot v. Commissioner of Social Security, 2023 WL 1413097, at *12 (N.D. Ohio Jan. 31, 2023)(followed)
  • M.G. v. Commissioner of Social Security, 861 F. Supp. 2d 846, 855 (E.D. Mich. 2012)(followed)
  • Woodall v. Colvin, 2013 WL 4710516, at *10 (N.D. Ohio Aug. 29, 2013)(followed)
  • Tate ex rel. Tate v. Commissioner of Social Security, 368 F. Supp. 2d 661, 663 (E.D. Mich. 2005)(followed)
  • Jordan v. Commissioner of Social Security, 548 F.3d 417, 422 (6th Cir. 2008)(followed)
  • Biestek v. Berryhill, 587 U.S. 97, 99, 102-03 (2019)(followed)
  • Bass v. McMahon, 499 F.3d 506, 509 (6th Cir. 2007)(followed)
  • Jones v. Commissioner of Social Security, 336 F.3d 469, 477 (6th Cir. 2003)(followed)
  • Lindsley v. Commissioner of Social Security, 560 F.3d 601, 605 (6th Cir. 2009)(followed)

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