Summary
The United States District Court for the Northern District of Ohio reviews Crystal Hodge’s challenge to the Commissioner of Social Security’s denial of Supplemental Security Income. The court holds that the newly submitted treatment records do not warrant a Sentence Six remand because they are cumulative and not material, and that the administrative law judge’s residual functional capacity assessment is supported by substantial evidence. The court affirms the Commissioner’s nondisability determination and overrules Hodge’s statement of errors.
Court
United States District Court for the Northern District of Ohio
Jurisdiction
United States District Court for the Northern District of Ohio
Decision date
March 13, 2026
Docket number
5:25-cv-01297-CEH
Disposition
affirmed
Questions Presented
- Whether a Sentence Six remand under 42 U.S.C. § 405(g) was warranted based on treatment records that were new, material, and supported by good cause.
- Whether the ALJ's assessment of Hodge's subjective symptoms and residual functional capacity was supported by substantial evidence.
Holdings
- Sentence Six remand was not warranted because, although the newly submitted Coleman Professional Services records were new and good cause existed for their late submission, Hodge failed to show that the records were material or that there was a reasonable probability they would have changed the disability determination.
- The ALJ's assessment of Hodge's symptom severity, consistency, and residual functional capacity was supported by substantial evidence.
- Hodge did not establish that her medication and treatment noncompliance was expressly linked to her mental impairments, and the ALJ therefore reasonably relied on the treatment gaps and noncompliance in evaluating symptom consistency.
Court Document
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