Summary
This Report and Recommendation addresses Beverly L. Yakel’s appeal under 42 U.S.C. § 405(g) from the denial of disability insurance benefits and supplemental security income. The magistrate judge recommends reversal and sentence-four remand because the Administrative Law Judge did not adequately evaluate the supportability and consistency of Dr. John Stafford’s medical opinion under the applicable regulations.
Holdings
- The ALJ did not adequately evaluate Dr. Stafford's opinion because the ALJ offered only vague observations concerning consistency and failed to address the opinion's supportability as required by the applicable regulations.
- The ALJ could properly find that the opinions expressed in the unsigned physical-assessment form were not persuasive because the form was neither signed nor clearly attributable to a medical source.
Questions Presented
- Whether the ALJ adequately evaluated Dr. Stafford's February 22, 2023 medical opinion for supportability and consistency under 20 C.F.R. §§ 404.1520c and 416.920c.
- Whether the Commissioner's denial of benefits was supported by substantial evidence.
Disposition
reversed_and_remanded
Cases Cited (19)
- Taskila v. Commissioner of Social Security, 819 F.3d 902, 903 (6th Cir. 2016)(followed)
- McKnight v. Sullivan, 927 F.2d 241 (6th Cir. 1991)(followed)
- Biestek v. Berryhill, 587 U.S. 97, 103 (2019)(followed)
- Young v. Secretary of Health and Human Services, 925 F.2d 146 (6th Cir. 1990)(followed)
- Brainard v. Secretary of Health & Human Services, 889 F.2d 679, 681 (6th Cir. 1989)(followed)
- Willbanks v. Secretary of Health & Human Services, 847 F.2d 301, 303 (6th Cir. 1988)(followed)
- Cutlip v. Secretary of Health and Human Services, 25 F.3d 284, 286 (6th Cir. 1994)(followed)
- Abbott v. Sullivan, 905 F.2d 918, 923 (6th Cir. 1990)(followed)
- Heston v. Commissioner of Social Security, 245 F.3d 528, 534 (6th Cir. 2001)(followed)
- Jones v. Commissioner of Social Security, 336 F.3d 469, 474 (6th Cir. 2003)(followed)
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Cited In (0)
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