Tyler Rayshon Thomas v. Frank Bisignano, Commissioner of Social Security

Thomas · United States District Court for the Northern District of Ohio, Eastern Division · February 11, 2026 · No. 1:23-cv-00612-BMB

Summary

This Report and Recommendation addresses Tyler Rayshon Thomas’s challenge to the Commissioner of Social Security’s denial of disability insurance benefits and supplemental security income. The magistrate judge recommends affirming the Commissioner’s decision, concluding that the ALJ applied proper legal standards and that substantial evidence supported the residual functional capacity determination, including the decision not to include a walker limitation.

Holdings

  1. The ALJ's decision not to include a walker requirement in the RFC was supported by substantial evidence and did not warrant remand.
  2. The ALJ properly applied SSR 16-3p and adequately articulated reasons, supported by substantial evidence, for discounting the severity of Thomas's subjective allegations.
  3. The challenge to the ALJ's evaluation of the state-agency medical consultants' findings failed because Thomas did not explain how consideration of a closed period would have changed the opinions' persuasiveness.

Questions Presented

  1. Whether the ALJ erred by failing to include a wheeled-walker limitation in Thomas's residual functional capacity.
  2. Whether the ALJ properly evaluated Thomas's subjective complaints under SSR 16-3p and 20 C.F.R. §§ 404.1529 and 416.929.
  3. Whether substantial evidence supported the ALJ's evaluation of the prior administrative medical findings.

Disposition

other

Cases Cited (25)

  • Combs v. Commissioner of Social Security, 459 F.3d 640, 642-43 (6th Cir.)(followed)
  • Rogers v. Commissioner of Social Security, 486 F.3d 234, 241, 248-49 (6th Cir.)(followed)
  • Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019)(followed)
  • Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)(followed)
  • Jones v. Commissioner of Social Security, 336 F.3d 469, 476-77 (6th Cir.)(followed)
  • Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir.)(followed)
  • Bowen v. Commissioner of Social Security, 478 F.3d 742, 746 (6th Cir.)(followed)
  • Rabbers v. Commissioner of Social Security Administration, 582 F.3d 647, 654 (6th Cir.)(followed)
  • Fleischer v. Astrue, 774 F. Supp. 2d 875, 877, 880 (N.D. Ohio)(followed)
  • Shrader v. Astrue, No. 11-13000, 2012 WL 5383120, at *6 (E.D. Mich. Nov. 1, 2012)(followed)

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