Automated Summary
Key Facts
Plaintiff Tami Lynn Firestone filed an application for Supplemental Security Income (SSI) on November 5, 2021, alleging disability onset of October 1, 2015 due to hypertension, kidney disease, blood clots, anxiety, high blood pressure, and high cholesterol. An administrative law judge held a hearing on June 26, 2023, and issued a decision on August 1, 2023, finding Firestone not disabled. The decision became final on June 11, 2024, when the Appeals Council declined further review. Firestone challenged this final decision in federal court. Medical evidence showed chronic kidney disease stage 3, history of deep vein thrombosis, and various abnormal blood work results. However, physical examinations were largely normal with well-controlled blood pressure and conditions. The court affirmed the Commissioner's final decision on July 7, 2025, finding the ALJ properly evaluated Firestone's symptoms and the decision was supported by substantial evidence.
Issues
- The court examined whether the ALJ properly applied the supportability and consistency factors when evaluating the medical opinion of Tricia Williams, APRN, CNP. Firestone argued the ALJ failed to identify inconsistencies between Williams' opinion and the record, while the Commissioner maintained substantial evidence supported the ALJ's finding that Williams' proposed limitations were not supported by her own treatment records.
- The court addressed whether the Administrative Law Judge properly evaluated the claimant's alleged fatigue symptoms in compliance with SSR 16-3p regulations. The plaintiff argued the ALJ failed to explain why she found the fatigue allegations incredible, while the Commissioner contended the ALJ properly considered relevant evidence and found symptoms not severe enough to preclude all work.
Holdings
The court affirmed the Commissioner's final decision denying Plaintiff Tami Lynn Firestone's application for Supplemental Security Income (SSI) benefits. The ALJ found the claimant had severe impairments including chronic kidney disease, deep vein thrombosis, anemia, hyperlipidemia, and hypertension, but determined she could perform past relevant work as a retail cashier/stocker with medium exertional level and occasional climbing and crawling limitations.
Legal Principles
- The court reviews the Commissioner's decision using the substantial evidence standard, which requires more than a scintilla of evidence but less than a preponderance. The court does not review evidence de novo, make credibility determinations, or weigh evidence. The Commissioner's decision must be supported by substantial evidence and made pursuant to proper legal standards.
- The two-step process for evaluating subjective symptoms: (1) whether medically determinable impairment could produce symptoms, and (2) evaluating intensity, persistence, and limiting effects of symptoms. Supportability and consistency are the most important factors for evaluating medical opinion evidence.
- The five-stage process for determining disability under Social Security regulations: (1) substantial gainful activity, (2) severe impairment, (3) meeting or medically equaling a listed impairment, (4) past relevant work, and (5) other work in the national economy.
Precedent Name
- Walters v. Comm'r of Soc. Sec., 127 F.3d 525, 531 (6th Cir. 1997)
- Kirk v. Sec'y of Health & Human Servs., 667 F.2d 524 (6th Cir. 1981)
- Abbott v. Sullivan, 905 F.2d 918, 923 (6th Cir. 1990)
- Ealy v. Comm'r of Soc. Sec., 594 F.3d 504, 512 (6th Cir. 2010)
- Heston v. Comm'r of Soc. Sec., 245 F.3d 528, 535 (6th Cir. 2001)
- Rogers v. Comm'r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)
- Ulman v. Comm'r of Soc. Sec., 693 F.3d 709, 714 (6th Cir. 2012)
- White v. Comm'r of Soc. Sec., 572 F.3d 272, 281 (6th Cir. 2009)
- Baker v. Colvin, No. 1:15-CV-00910, 2016 WL 4128435, at *13 (N.D. Ohio Aug. 3, 2016)
Cited Statute
- Social Security Act SSI provisions
- Social Security Act
- Magistrate Judge consent jurisdiction
Judge Name
Jonathan D. Greenberg
Passage Text
- In determining whether an ALJ's findings are supported by substantial evidence, the Court does not review the evidence de novo, make credibility determinations, or weigh the evidence. An ALJ's determination of subjective evidence receives great deference on review.
- For the foregoing reasons, the Commissioner's final decision is AFFIRMED. IT IS SO ORDERED. Dated: July 7, 2025
- After careful consideration of the evidence, the undersigned finds that the claimant's medically determinable impairments could reasonably be expected to cause the alleged symptoms; however, the claimant's statements concerning the intensity, persistence, and limiting effects of these symptoms are not entirely consistent with the objective evidence of record and other evidence.