Summary
This Report and Recommendation addresses Gregory Lee Boetticher’s action seeking judicial review of the Commissioner of Social Security’s denial of Supplemental Security Income. The magistrate judge concludes that the Administrative Law Judge applied proper legal standards and supported the residual functional capacity assessment with substantial evidence, and recommends affirming the Commissioner’s decision.
Holdings
- An ALJ's residual-functional-capacity determination need not be based on a physician's opinion consistent with the ALJ's finding; the dispositive inquiry is whether the RFC is supported by substantial evidence and results from application of proper legal standards.
- The ALJ adequately explained and supported the RFC limitations by relying on the medical record and testimony, including preserved grip strength and range of motion, thenar atrophy, the carpal-tunnel diagnosis, reported dropping of objects, and the claimant's ability to perform activities involving his upper extremities.
- The Commissioner's final decision denying Boetticher's SSI application should be affirmed because the ALJ applied proper legal standards and reached a decision supported by substantial evidence.
Questions Presented
- Whether the ALJ improperly relied on lay medical judgment rather than medical opinion evidence in assessing Boetticher's residual functional capacity.
- Whether the ALJ's residual-functional-capacity finding regarding overhead reaching, handling, and fingering was supported by substantial evidence and adequately explained.
Disposition
other
Cases Cited (31)
- Combs v. Commissioner of Social Security, 459 F.3d 640, 642-43 (6th Cir. 2006)(applied)
- Rogers v. Commissioner of Social Security, 486 F.3d 234, 241 (6th Cir. 2007)(applied)
- Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019)(applied)
- Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)(applied)
- Jones v. Commissioner of Social Security, 336 F.3d 469, 476-77 (6th Cir. 2003)(applied)
- Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986)(applied)
- Bowen v. Commissioner of Social Security, 478 F.3d 742, 746 (6th Cir. 2007)(applied)
- Rabbers v. Commissioner of Social Security Administration, 582 F.3d 647, 654 (6th Cir. 2009)(applied)
- Fleischer v. Astrue, 774 F. Supp. 2d 875, 877 (N.D. Ohio 2011)(applied)
- Shrader v. Astrue, No. 11-13000, 2012 WL 5383120, at *6 (E.D. Mich. Nov. 1, 2012)(applied)
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