Case Name in Social Security Case - Unavailable

THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
VALARIE JO MARZOLF,
Plaintiff,
V.
FRANK BISIGNANO,
Commissioner of Social Security,
Defendant.
: CIVIL ACTION NO. 1:25-CV-47
: (JUDGE MARIANI)
: (Magistrate Judge Camoni)
Ji. 	ORDER
AND NOW, THIS ~ 	bAv OF MARCH 2026 , upon de nova review of
Magistrate Judge Sean A. Camoni's Report and Recommendation (''R&R") (Doc. 18) ,
Pla intiffs objection thereto (Doc . 19), and other relevant documents, IT IS HEREBY
ORDERED THAT:
1. Plaintiffs object ion (Doc . 19) is OVERRULED .
Plaintiff asserts that the Magistrate Judge erred in finding that the ALJ's
supportability analysis was proper under the regu lations. 	(Doc. 19 at 1.) The
Court disagrees. The objection is based on Plaint iffs conclusion that the ALJ 's
analysis did not specifically include the findings of Ahmed Kneifati, M.D ., a
consultative examiner, regarding ankle range of motion , obesity, tender left
lateral hip, and pulmonary findings . (Id . at 2.) An ALJ is required to articulate
his conclusions regarding medical opinions , 20 C.F.R. § 404 .1520c(b), and
specifically explain how the "supportability factor " of a medical source's opinion
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was considered, 20 C.F.R. § 404.1520c(b)(2). 1 As a general matter, it has long
been recognized that all evidence need not be reviewed and the ALJ need not
use "magic language" or adhere to a particular analytical format when
considering opinion evidence in accordance with the applicable regulations.
Caruso v. Comm 'rof Soc . Sec., 99 F. App'x 376,379 (3d Cir. 2004) (citing
Burnett v. Comm 'r of Soc. Sec ., 220 F.3d 112, 120 (3d Cir. 2000)); Diaz v.
Comm 'r of Soc. Sec. , 577 F.3d 500 , 504 (3d Cir. 2009);2 see also Tyler E. K. v.
Comm'r of Soc. Sec., Civ. A. No . 21-9623, 2022 WL 3913559 , at *6 (D.N.J. Aug .
31, 2022) (finding that the ALJ appropriately considered the supportability and
consistency factors by citing the physician's treatment notes and other evidence
in the record). 	As indicated in Zaborowski v. Comm 'r of Soc . Sec ., 115 F.4th
637 (3d Cir. 2024), the supportability requirement can be satisfied when an ALJ
"weave[s] supportability ... throughout [the] analysis of which doctors were
persuasive." Id. at 639. A recent Third Circuit panel decision is instructive on
the 20 C.F.R. § 404.1520c(b)(2) requirement that an ALJ articulate consideration
of the supportability requirement. The panel in Olinger v. Comm'r Soc. Sec., No.
1 20 C.F.R. § 404.1520c further explains the supportability factor as follows : "The more relevant the
objective medical evidence and supporting explanations presented by a medica l source are to support his
or her medical opinion(s) or prior administrative medical finding(s) , the more persuasive the medical
opinions or prior administrative medical finding(s) will be ." 20 C.F.R. § 404 .1520c(c)(1 ).
2 Diaz noted that
[i]n Burnett, we held that an ALJ must clearly set forth the reasons for his decision . Burnett [v . Comm 'r
of Soc. Sec. , 220 F.3d 112, 199 (3d Cir . 2000)] . Conclusory statements that a condition does not
constitute the medica l equivalent of a listed impairment are insufficient. The ALJ must provide a
"discussion of the evidence " and an "explanation of reasoning " for his conclusion sufficient to enable
meaningful judicial review . Id . at 120 ; see Jones v. Barnhart, 364 F.3d 501 , 505 & n. 3 (3d Cir.2004) .
The ALJ , of course , need not employ particular "magic " words: "Burnett does not require the ALJ to
use particu lar language or adhere to a particular format in conduct ing his analysis. " Jones , 364 F.3d
at 505 .
Diaz v. Comm 'r of Soc . Sec. , 577 F.3d 500 , 504 (3d Cir . 2009) .
2
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24-3275 , 2025 WL 3216408 (3d Cir. Nov. 18, 2025), found that the ALJ
evaluated supportability when she determined that:
[a 	treating 	nurse 	practitioner's] 	opinions 	are 	not
persuasive because they ... are not fully supported
by 	the 	clinical 	signs 	and 	findings 	including 	an
examination 	in 	February 	2021 	showing 	that 	the
claimant appeared in no distress with a normal gait,
no muscle spasms, [and] no pain with palpation of the
lumbar spine.
App . 34. 	. . . 	The ALJ satisfied the supportability requirement
because she used objective medical evidence, or "clinical signs and
findings" to eva luate the persuasiveness of [the treating nurse
practitioner's] opinion. App. 34.
2025 WL 3216408, at *2-3. 	Here , the ALJ used "objective medical evidence, or
'clinical signs and findings' to evaluate the persuasiveness" of Dr. Kneifati 's
opinion . Id. 	As the Magistrate Judge recognizes , the ALJ reviewed Dr.
Kneifati's own treatment notes before discussing the medical opinion and used
Dr . Kneifati's own medical findings to support his conclusion that Dr . Kneifati's
opinion was "unpersuasive ." (See Doc.18 at 10-11 (citing ALJ Decision, Doc .
11-2 at 20-22) .) In his Decision, the ALJ stated that he found Dr . Kneifati's
opinion
unpersuasive as it is unsupported by his own examination of the
claimant as Dr. Kneifati found the claimant had a normal gait;
normal strength; ability to walk on heels and toes without difficulty;
had a normal stance and was able to get on and off the exam table
without assistance . (Ex. 3F/5) . . . . Furthermore, the claimant has
reported 	improvement 	in 	her 	asthma 	since 	Singulair 	was
prescribed; 	she 	had 	normal 	respiratory 	effort ; her 	chest 	wall
movement was symmetrical; lungs were clear bilaterally; no cracks
were noted; she did not cough with forced exhalat ion; and due to
3
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her 	mild 	plantar 	fasciitis , 	conservative 	treatment 	was
recommended. 	(Ex. 5F/12 , 33; 6F/10).
(Doc . 11-2 at 22.) 	Because the ALJ's consideration of the supportability factor is
consistent with that found acceptable by the Third Circuit panel in Olinger, 2025
WL 3216408 , at *3, as well as the articulation requirements set out in 20 C.F.R.
§ 404.1520c(b )(2) and guidance provided in Zaborowski, 115 F.4th at 639 ,
Magistrate Judge Camoni did not err in finding that the ALJ's consideration of Dr.
Kneifat i's opinion satisfied the requisite supportability factor.
2. 	The R&R (Doc. 18) is ADOPTED for the reasons set forth therein .
3. Plaint iffs appeal of the Acting Commissioner's decision (Doc. 1) is DENIED.
United States District Judge
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