Summary
This Report and Recommendation addresses Delaney A. McCoy’s challenge to the denial of child’s insurance benefits and supplemental security income. The magistrate judge recommends affirming the Commissioner of Social Security’s decision, concluding that the ALJ properly considered the educational records, medical opinions, and other evidence under the applicable Social Security standards. The recommendation applies substantial-evidence review and the five-step disability-evaluation framework.
Holdings
- The ALJ complied with Social Security Ruling 11-2p by considering McCoy's educational records, including the teacher's statement and Section 504 Plans; the ruling required consideration of relevant school records but did not require adoption of particular limitations suggested by those records.
- The ALJ adequately explained the supportability and consistency factors in evaluating the challenged medical opinions and reasonably determined that the opinions were unpersuasive or only partially persuasive.
- The ALJ's residual functional capacity determination was supported by substantial evidence and adequately accounted for McCoy's seizure-related limitations.
Questions Presented
- Whether the ALJ evaluated McCoy's educational records consistently with Social Security Ruling 11-2p.
- Whether the ALJ adequately explained the persuasiveness of the medical opinions under the supportability and consistency requirements of 20 C.F.R. § 416.920c.
- Whether the ALJ's residual functional capacity assessment adequately accounted for McCoy's psychogenic non-epileptic seizures and alleged stress-related limitations.
Disposition
other
Cases Cited (25)
- McClanahan v. Comm'r of Soc. Sec., 193 F. App'x 422, 425 (6th Cir. 2006)(followed)
- Jordan v. Comm'r of Soc. Sec., 548 F.3d 417, 422-23 (6th Cir. 2008)(followed)
- Walters v. Comm'r of Soc. Sec., 127 F.3d 525, 529 (6th Cir. 1997)(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. Comm'r of Soc. Sec., 336 F.3d 469, 477 (6th Cir. 2003)(followed)
- Lindsley v. Comm'r of Soc. Sec., 560 F.3d 601, 605 (6th Cir. 2009)(followed)
- Felisky v. Bowen, 35 F.3d 1027, 1035 (6th Cir. 1994)(followed)
- Heckler v. Edwards, 465 U.S. 870, 873 n.1 (1984)(followed)
- Anthony L. v. Comm'r of Soc. Sec., No. 1:22-CV-605, 2023 WL 5349509, at *4 (S.D. Ohio Aug. 21, 2023)(followed)
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