3:25-cv-00308•Case Name in Social Security Case - Unavailable
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AUTHENTICAT Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 1 of 44 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA NICOLE L. POFF, : No. 3:25-CV-308 Plaintiff, : (Brann, C.J.) Vv. : (Caraballo, M.2J.) FRANK BISIGNANO,! Commissioner of Social Security, Defendant REPORT AND RECOMMENDATION I. Introduction Plaintiff Nicole L. Poff seeks judicial review of the final decision of the Commissioner of Social Security (the “Commissioner”) denying her application for disability insurance benefits and supplemental security income under Titles IIT and XVI of the Social Security Act. The Court has jurisdiction pursuant to 42 U.S.C. § 405(g). This matter was referred to the undersigned to prepare a report and recommendation addressing the merits of two alleged errors that 1Frank Bisignano was confirmed as the Commissioner of the Social Security Administration on May 6, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure and 42 U.S.C. § 405(g), Frank Bisignano is substituted as the defendant in this suit. Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 2 of 44 the Administrative Law Judge (“ALJ”) committed when determining that Poff was not disabled under the Social Security Act. Namely, Poff claims that the ALJ erred when he evaluated: (1) the medical opinions of treating source Jennifer Clark, C.R.N.P., and consultative examiner Karena Hammon, N.P; and (2) Poff’s subjective symptom complaints. Doc. 13 at 2-15. The matter is fully briefed and ripe for decision. As explained below, the ALJ’s conclusions when addressing both challenged issues were supported by substantial evidence in the record, coupled with sufficient reasoning to permit meaningful judicial review. Accordingly, the undersigned respectfully recommends that the Court affirm the Commissioner’s decision to deny Poff’s claim for social security disability benefits and supplemental security income. II. Background On January 10, 2023, Poff applied for both social security disability insurance benefits and supplemental security income. Doc. 8 at 215-53 (hereinafter referred to as “Tr.”). Poff alleged complete disability in these applications from a myriad of impairments, including herniated discs, degenerative disc disease, scoliosis, bilateral knee surgeries, psoriatic arthritis, fibromyalgia, rheumatoid arthritis, Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 3 of 44 bilateral carpal tunnel syndrome, left arm tendinitis, and bilateral plantar fasciitis. Id. at 82. Poff's applications were initially denied in October 2028. Id. at 93, 107. After her claims were denied on reconsideration in March 2024, Poff requested a hearing before an ALJ. Id. at 156. On September 13, 2024, ALJ Howard Kauffman presided over Poff's hearing. The hearing concerned whether Poff was disabled within the meaning of the Social Security Act since December 5, 2022. Tr. 17. At the hearing, ALJ Kauffman received various evidence of record, including clinical records, medical history, medical expert reports, vocational expert testimony, and Poff’s own testimony. Jd. at 32-81. On September 19, 2024, ALJ Kauffman issued a decision concluding that Poff was not disabled between the operative dates of December 5, 2022, through the date of the decision. Jd. at 14-17, 31. ALJ Kauffman reached that conclusion by employing a five-step analytical process required under the Social Security Act to evaluate disability insurance and supplemental security income claims. See 20 C.F.R. § 404.1520(a)(4). Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 4 of 44 The process requires sequential consideration of: (1) whether the claimant is engaged in substantial gainful work activity; (2) the medical severity of the claimant’s impairments; (8) whether the impairment meets or equals a defined list of impairments; (4) a comparison between the claimant’s past relevant work and residual functional capacity, 1.e., the most work that a claimant can perform despite his or her limitations, see 20 C.F.R. § 404.1545(a); and (5) an assessment of the claimant’s residual functional capacity and his or her age, education, and work experience. 20 C.F.R. § 404.1520(a)(4)G)-(v). Should a claimant proceed past the first three steps of the analysis, the Commissioner will not find the claimant disabled when he or she can perform past relevant work, or adjust to other work, under the third and fourth steps, respectively. Id. at § 404.1520(a)(4)av)-(v), (f), (g). Applying that analysis, ALJ Kauffman first determined that Poff met the insurance requirements of the Social Security Act, see 20 C.F.R. § 404.130, through December 31, 2026. Tr. 19. ALJ Kauffman also found that Poff had not engaged in substantial gainful activity between her alleged disability onset date of December 5, 2022, through the date of the decision. Id. Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 5 of 44 At the second step of the analysis, ALJ Kauffman found that Poff suffered from eight severe impairments: degenerative joint disease of the right knee, degenerative disc disease of the lumbar spine, migraine headaches, obesity, psoriatic arthritis, fibromyalgia, and tachycardia. Id. at 20. ALJ Kauffman also identified several non-severe impairments, including mild obstructive sleep apnea, gastroesophageal reflux disease, hyperlipidemia, hypertension, restless leg syndrome, carpal tunnel syndrome, depression, anxiety, and intermittent explosive disorder. Id. at 20-22. He found that the evidence showed such conditions had significantly improved and caused “no more than ‘mild’ limitation in any of the functional areas... .” Jd. at 20-21. Moving to the third step of the analysis, ALJ Kauffman determined that Poffs eight severe impairments failed to meet or medically equal one of the impairments listed in the Social Security Administration’s regulations. Id. at 22. Poff thus did not automatically qualify as disabled. See 20 C.F-.R. § 404.1520(a)(4)@ii) (“Tf you have an impairment(s) that meets or equals one of our listings in appendix 1 of this subpart and meets the duration requirement, we will find that you are disabled.”). Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 6 of 44 Accordingly, ALJ Kauffman proceeded to determine Poff’s residual functional capacity, before addressing the final two steps in the sequential analysis. Based on the evidence of record, ALJ Kauffman concluded that Poff could perform sedentary work: After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a) except she can occasionally climb ramps and stairs and occasionally balance, stoop, kneel, crouch, and crawl, she cannot climb ladders, ropes, or scaffolds, no concentrated exposure to extreme cold, extreme heat, vibration, fumes, dusts, gases, odors, poor ventilation, unprotected heights, and moving machine parts. Tr. 22-23. In reaching that conclusion, ALJ Kauffman considered three pieces of evidence germane to this opinion. First, he considered Poff’s testimony regarding her impairment symptoms: The claimant alleges disability due to chronic pain with psoriasis arthritis as well as osteoarthritis, fibromyalgia, and migraine headaches. The claimant testified that she underwent two knee surgeries previously and that she is unable to squat, bend, or kneel and has difficulty with stairs. She testified that her knee gives out and that she has pain and swelling in her joints, worse with cold, rain, and snow. She testified to widespread pain and fatigue due to fibromyalgia. She testified that she uses a cane at times but that it was not prescribed. She testified to migraine headaches and that she feels lightheaded and dizzy at times. She testified to weight loss with her weight down to 270 6 Case 3:25-cv-00308-MWB ~.Document17 _ Filed 01/13/26 Page 7 of 44 pounds from 390 pounds and that 60 pounds was “water” weight (Hearing Testimony). The claimant alleges difficulty lifting, standing, reaching, walking, sitting, using her hands, and concentrating (Exhibit 9E). Id. at 23. In reviewing that testimony, in comparison to the record, ALJ Kauffman concluded “that the claimant’s medically determinable impairments could reasonably be expected to cause the alleged symptoms.” Id. The ALJ found, however, that Poff’s “statements concerning the intensity, persistence and limiting effects of these symptoms are not entirely consistent with the medical evidence and other evidence in the record... .” Jd. In particular, ALJ Kauffman ultimately concluded that “[w]hile the combination of the claimant’s severe impairments limits her to work within the sedentary exertional level with additional non- exertional limitations, the medical evidence of record,” including various treatment notes, Poff's own testimonial statements, and examination findings, collectively failed to “support a finding of disability in this case.” Jd. at 29 (citing Exhibits 3F, 4F, 5F, 11F, 14F, 21F, 22F, 23F, and Hearing Testimony). Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 8 of 44 Second, ALJ Kauffman evaluated the persuasiveness of the medical opinion of consultative examiner Karena Hammon, N.P., in determining the limitations imposed by Poff’s physical impairments. He specifically considered Nurse Hammon’s assessment that Poff: [Clan lift ten, twenty, and up to fifty pounds occasionally. She can carry ten and twenty pounds occasionally. She can sit for three hours at one time for a total of six hours in an eight- hour workday. She can stand for 30 minutes at one time for a total of two hours in an eight-hour workday. She can walk for 15 minutes at one time for a total of two hours in an eight- hour workday. She does not require the use of a cane to ambulate. She can reach, including overhead, handle, finger, feel, push and pull frequently with either hand. She can operate bilateral foot controls occasionally. She can never balance, kneel, or crouch. She can occasionally climb stairs and ramps, ladders or scaffolds, stoop, and crawl. She can never tolerate exposure to unprotected heights, moving mechanical parts, humidity, wetness, dust, odors, fumes, pulmonary irritants, extreme cold, and extreme heat. She can tolerate occasional exposure to operating a motor vehicle and vibrations. She can tolerate a moderate noise work environment. She is unable to walk a block at a reasonable pace or climb a few steps at a reasonable pace with the use of a single hand rail (Exhibit 8F). Id. at 26. Although the ALJ considered Nurse Hammon’s assessment of Poffs functional abilities, he afforded it only partial persuasive value, finding some of its limitations inconsistent with and unsupported by other evidence of record, including the clinical records, treatment notes, 8 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 9 of 44 and examination findings. Jd. (citing Exhibits 4F, 5F, 10F, 11F, 14F, 21F, 22F, 23F, and 26F). Third, ALJ Kauffman evaluated the persuasiveness of the medical opinion of treating source Jennifer M. Clark, C.R.N.P., in determining the limitations imposed by Poffs physical and mental impairments. He specifically considered Nurse Clark’s assessment that Poff’s symptoms: [Wlould frequently interfere with attention and concentration. She is unable to work in a competitive environment, even a sedentary occupation, on a full time basis. She can walk one block without rest. She can walk for 20-30 minutes at a time, stand for 20-20 minutes at a time, and sit for 20-30 minutes at a time before needing to change position. She can sit, stand, and/or walk for a total of four hours in an eight-hour workday. She would need unscheduled breaks for 15-30 minutes for 75 minutes. The claimant has good days and bad days and would likely be absent from work about three times a month. She must use a cane or other assistive device while engaging in occasional standing/walking. She has significant limitations in performing repetitive reaching, handling, or fingering. She can lift and carry five pounds frequently and ten pounds occasionally. She can never carry more than ten pounds (Exhibit 15F). On June 3, 2024, Nurse Clark again assessed the claimant’s functional abilities: her symptoms would often interfere with her attention and concentration. She would need to elevate her legs four times during a normal workday. She can sit for 30 minutes at one time for a total of four hours in an eight-hour workday. She can stand or walk for 30 minutes at one time for a total of four hours each in an eight- hour workday. She would need unscheduled 15-30 minute breaks for 75 minutes during the workday. She can lift and carry less than ten pounds frequently and ten pounds 9 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 10 of 44 occasionally. She can frequently balance. She can never stoop, kneel, and crouch. She can use her hands, fingers, and arms each for 50% of the workday. She would be absent from work more than four times a month (Exhibit 24F). On January 9, 2024, Nurse Clark assessed the claimant’s mental functional abilities: she has a marked (serious limitation in the area and cannot generally be performed satisfactorily) limitation in her ability to maintain attention and concentration for extended periods of time. She has a moderate (intermittent difficulty performing in the area and cannot “always” be performed satisfactorily) limitation in her ability to understand and remember short and simple instructions, perform activities on schedule and maintain regular attendance, complete a normal workweek and workday without interruptions, and perform at a consistent pace with a standard number and length of breaks. She has a minimal (mild limitation but can generally function satisfactorily) limitation in her ability to understand and remember detailed instructions, perform simple and detailed instructions, sustain an ordinary routine without special supervision, and make simple work-related decisions. She has no limitation in terms of social interaction. She would be expected to be off-task 15-20% of the workday due to psychologically based symptoms (Exhibit 15F). On June 3, 2024, Nurse Clark again assessed the claimant's mental functional abilities. She found that the claimant’s abilities and limitations remained unchanged compared to her prior January 2024 opinion, as noted above (Exhibit 25F). Tr. 28. After considering Nurse Clark’s assessment of Poff’s functional abilities, ALJ Kauffman did not afford it persuasive value, finding its 10 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 11 of 44 limitations inconsistent with and unsupported by other evidence of record, including Nurse Clark’s own examination notes, other medical treatment notes, and other examination findings, he. Id. at 28-29 (citing Exhibits 4F, 5F, 10F, 11F, 12F, 14F, 21F, 22F, 23F, and 26F). Based on these three findings, among others, ALJ Kauffman deemed Poff capable of performing sedentary work subject to limitations. This brought him to the fourth step of the analysis, to determine whether Poff was disabled within the meaning of the Social Security Act. Here, with assistance from a vocational expert’s testimony, ALJ Kauffman compared Poff’s past relevant work and residual functional capacity, finding that Poff was unable to perform her prior employment as an inventory clerk. Jd. at 29. Finally, in the fifth step of the sequential analysis process, ALJ Kauffman considered Poffs age, education, work experience, and residual functional capacity to perform sedentary work, concluding that “there are jobs that exist in significant numbers in the national economy that the claimant can perform|[.]” Jd. at 30. Here, ALJ Kauffman again leveraged testimony from a vocational expert, who advised that an individual fitting Poffs parameters could perform the 11 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 12 of 44 occupational requirements of a ticket checker, appointment clerk, or table worker. Tr. 30. As a result of this analysis, ALJ Kauffman determined that Poff was not disabled and denied her application for disability benefits. Id. at 28. Poff unsuccessfully appealed the decision to the Social Security Administration’s Appeals Council, which denied Poff’s request to review ALJ Kauffman’s decision on December 26, 2024. Id. at 1. Having exhausted her administrative remedies, Poff’s instant appeal to the district court followed. Poff initiated this action with the Court on February 20, 2025. Doc. 1. The Commissioner filed an answer and provided the requisite transcripts from the disability proceedings on May 28, 2025. Docs. 7, 8. The parties then filed their respective briefs, Docs. 13, 15-16, with Poff alleging two errors warranting reversal or remand, Doc. 18 at 2-15. Specifically, Poff avers that ALJ Kauffman: (1) erred when evaluating the medical opinions authored by Nurses Clark and Hammon, contending that his articulation of the supportability and consistency of these opinions was insufficient to permit meaningful judicial review; and that he (2) did not have substantial evidence to 12 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 13 of 44 support his finding that Poff’s subjective symptom testimony was not supported by the record. Id. Ill. Discussion A. Standard of Review Review of the Commissioner’s decision denying a claimant’s application for social security disability benefits is limited to determining whether the factual findings of the final decisionmaker are supported by substantial evidence in the record. See 42 U.S.C. § 405(g); Johnson v. Comm’ of Soc. Sec., 529 F.3d 198, 200 (8d Cir. 2008). Substantial in this context is “more than a mere scintilla of evidence but may be less than a preponderance.” Brown v. Bowen, 845 F.2d 1211, 1213 (8d Cir. 1988). Put more pointedly, it is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Pierce v. Underwood, 487 U.S. 552, 565 (1988) (quoting Consol. Edison Co. v. N.L.R.B., 305 U.S. 197, 229 (1988)) (citations omitted). In an adequately developed record, this can mean “something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.” Consolo v. Fed. 13 Case 3:25-cv-00308-MWB Document17_.Filed 01/13/26 Page 14 of 44 Maritime Comm 'n., 383 U.S. 607, 620 (1966). Under this highly deferential standard, “[f]actual findings which are supported by substantial evidence must be upheld.” Ficca v. Astrue, 901 F. Supp. 2d 533, 5386 (M.D. Pa. 2012) (emphasis added); 42 U.S.C. § 405(g). Thus, the Court’s role under this standard is not to re-weigh the evidence and make factual determinations, but to simply review the record to ensure factual findings are supported by substantial evidence, and to confirm that the ALJ provided a “discussion of the evidence and explanation of reasoning for his conclusion sufficient to enable judicial review.” Diaz v. Comm’ of Soc. Sec., 577 F.3d 500, 504 (38d Cir. 2009) (citations omitted). And although an ALJ’s decision must “reasonably articulat[e]” its reasoning so “a subsequent reviewer or a reviewing court” can trace its path, 82 Fed. Reg. 5844-01, 5858 (2017), an ALJ need only give “some indication” of their consideration of probative evidence to successfully carry this burden of articulation. Burnett v. Comm’ of Soc. Sec. Admin., 220 F.3d 112, 121 (8d Cir. 2000). In practical terms, this means that when there is countervailing, probative evidence, an ALJ must “give some reason for discounting the evidence she rejects.” Plummer v. Apfel, 186 F.3d 422, 429 (8d Cir. 14 ‘Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 15 of 44 1999); cf. Mason v. Shalala, 994 F.2d 1058, 1064 (8d Cir. 1998) (holding that the substantial evidence standard is unmet when an ALJ fails to resolve a conflict created by countervailing evidence.). In the context of evaluating the persuasiveness of medical opinions, which are often some of the most probative evidence available, an ALJ is required to assess the level of support and consistency the opinion has against the record. 20 C.F.R. § 404.1520c. Here, ALJ Kauffman’s factual findings were supported by substantial evidence in the record, and the reasoning underlying those conclusions was sufficiently articulated to permit judicial review. B. The ALJ’s Evaluation of the Medical Opinions of Nurse Clark and Nurse Hammon Poff contends that ALJ Kauffman erred in his evaluation of the favorable medical opinions of Karena Hammon, N.P., a consulting examiner, and Jennifer Clark, a treating C.R.N.P. Poff argues that the ALJ did not provide a sufficient explanation concerning the supportability and consistency of these opinions in finding that they were partly persuasive and unpersuasive, respectively. Doc. 13 at 2-15. As set forth below, the ALJ’s evaluation of the persuasive value of these 15 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 16 of 44 two opinions sufficiently assessed their supportability and consistency, and his findings regarding each are supported by substantial evidence. When evaluating a medical opinion, an ALJ is required to assess the level of support and consistency the opinion has against the record. 20 C.F.R. § 404.1520c. The supportability of a medical opinion “increases as the relevance of the objective medical evidence and explanations presented by the medical source increases.” Vellone v. Saul, 2021 WL 319354, at *6 (S.D.N.Y. 2021), report and recommendation adopted, 2021 WL 2801138 (8.D.N.Y. 2021) (citing 20 C.F.R. § 404.1520c(c)(1)). The consistency assessment is “an all- encompassing inquiry focused on how well a medical source is supported, or not supported, by the entire record.” Clay v. Kijakazt, 2022 WL 13989015, at *3 (N.D. Miss. 2022) (quoting 20 C.F-.R. § 404.1520c(c)(1)). Because an ALJ’s duty of articulation requires just “some indication” of their consideration of probative evidence, Burnett, 220 F.3d at 121, an ALJ’s assessment of a medical opinion’s consistency and supportability “need not discuss every piece of evidence in the record,” and instead simply requires the building of “ ‘an accurate and logical 16 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 17 of 44 bridge between the evidence and the result.’” Gamret v. Colvin, 994 F. Supp. 2d 695, 698 (W.D. Pa. 2014) (quoting Hodes v. Apfel, 61 F.Supp.2d 798, 806 (N.D. Il. 1999); and Sarchet v. Chater, 78 F.3d 305, 307 (7th Cir. 1996)). Further, in assessing whether an ALJ has provided an adequate analysis for rejecting or accepting an opinion, the court must look to the opinion as a whole, not only the part directly addressing the particular opinion. See Jones v. Barnhart, 364 F.3d 501, 505 (8d Cir. 2004) (“[T]he ALJ’s decision, read as a whole, illustrates that the ALJ considered the appropriate factors in reaching the conclusion that [claimant] did not meet the requirements for any listing[.]”). The sufficiency of an evaluation turns on the extent to which its reasoning is driven by an ALJ’s read of the evidence—and the court’s ability to discern that evidentiary reasoning. See, e.g., Price v. Astrue, A401 F. App’x 985, 986 (Sth Cir. 2010) (‘The ALJ does not need to comment on every piece of evidence, but only must build an accurate and logical bridge between the evidence and the final determination.”) (citing Glomski v. Massanari, 172 F. Supp. 2d 1079, 1082, (E.D. Wis. 2001)); Acosta Cuevas v. Comm’ of Soc. Sec., 2021 WL 363682, at *15 17 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 18 of 44 (S.D.N.Y. 2021), report and recommendation adopted sub nom., 2022 WL 717612 (S.D.N.Y. 2022) (“[t]he ALJ must provide a reviewing Court with a sufficient explanation to ensure that they have complied with the legal procedures controlling their decision and cannot ignore or mischaracterize evidence.”). 1. Nurse Hammon’s Opinion Nurse Hammon performed a consultative examination of Poff on September 9, 2023. Tr. 782. As explained by the ALJ, Nurse Hammon found, in relevant part, that Poff could: [Lift ten, twenty, and up to fifty pounds occasionally. She can carry ten and twenty pounds occasionally. She can sit for three hours at one time for a total of six hours in an eight- hour workday. She can stand for 30 minutes at one time for a total of two hours in an eight-hour workday. She can walk for 15 minutes at one time for a total of two hours in an eight- hour workday. She does not require the use of a cane to ambulate. She can reach, including overhead, handle, finger, feel, push and pull frequently with either hand. She can operate bilateral foot controls occasionally. She can never balance, kneel, or crouch. She can occasionally climb stairs and ramps, ladders or scaffolds, stoop, and crawl. She can never tolerate exposure to unprotected heights, moving mechanical parts, humidity, wetness, dust, odors, fumes, pulmonary irritants, extreme cold, and extreme heat. She can tolerate occasional exposure to operating a motor vehicle and vibrations. She can tolerate a moderate noise work environment. She is unable to walk a block at a reasonable pace or climb a few steps at a reasonable pace with the use of a single hand rail. 18 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 19 of 44 Id. at 26, 788-938. In evaluating Hammon’s findings, ALJ Kauffman concluded that they were “partially persuasive,” specifically crediting those portions regarding Poff’s “ability to sit, stand, and walk and that she does not require the use of an assistive device to ambulate,” because ALJ Kauffman himself found these “supported by the claimant’s presentation that day.” Id. at 26. However, the ALJ concluded that Hammon’s conclusions regarding Poff’s ability to lift weight, “use her hands, operate foot controls, or tolerate only a moderate noise environment,” unpersuasive, because they were not supported by her “presentation that day or by her clinical history,” and inconsistent with her “other physical examination findings and overall symptomatic improvement with treatment in terms of her psoriasis, lower extremity edema, knee pain, migraine headaches, and weight loss.” Id. This evaluation of Hammon’s opinion, challenged by Poff now on appeal, sufficiently discussed the evidence and was reasonably articulated to permit meaningful judicial review. The ALJ set forth his evidence-based reasoning for deeming unpersuasive those portions of Hammon’s opinion concerning Poff’s 19 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 20 of 44 ability to lift weight, use her hands, operate foot controls, and tolerate a moderate noise environment. Specifically, ALJ Kauffman explained that Poffs examination and clinical history did not support Nurse Hammon’s opinions on those factors, which he also found inconsistent “with the claimant’s other physical examination findings and overall symptomatic improvement with treatment in terms of her psoriasis, lower extremity edema, knee pain, migraine headaches, and weight loss.” Tr. 26. In support of that conclusion, ALJ Kauffman cited a series of exhibits, without precise details concerning their relevance; an approach that Poff deems “cursory” and an inarticulate “string citation.” Doc. 13 at 5-6. Although those characterizations bear an element of truth, and the ALJ’s analytical approach does not engender effective judicial review, it does not thwart meaningful judicial review. “A written evaluation of every piece of evidence is not required, as long as the ALJ articulates at some minimum level her analysis of a particular line of evidence. Moreover, the ALJ’s mere failure to cite specific evidence does not establish that the ALJ failed to consider it.” Phillips v. Barnhart, 91 F. App’x 775, 780 n.7 (8d Cir. 2004) Gnternal citation 20 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 21 of 44 omitted). And a review of the cited evidence of record supports the ALJ’s conclusions on the consistency and supportability of Nurse Hammon’s opinions. In Nurse Hammon’s relevant physical examination findings, she found that Poff had 4/5 bilateral grip strength, that she could manipulate a coin, pen, and cup without difficulty, that she had no evident muscle atrophy, and that her joints were stable and non- deformed. Tr. at 784—86. The treatment evidence identified by the ALJ likewise showed that, most recently, Poff’s psoriasis had largely cleared up with treatment (id. at 1036), that she no longer had edema (id. at 981), that her right knee had returned to its baseline prior to a previous injury and that knee injections were providing additional relief as needed (id. at 929, 935), that her migraines were well under control and that she reportedly did not have very many (id. at 828, 967), and that she had lost 85 pounds by watching her diet and staying active (id. at 981). Moreover, although ALJ Kauffman did not address these medical findings in the section of his opinion deeming a portion of Nurse 21 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 22 of 44 Hammon’s opinion unpersuasive, he did review them elsewhere in the opinion. Namely, the ALJ stated: [Poff] presented [at her examination with Nurse Hammon] with normal reflexes, no sensory deficit, 4/5 strength in her upper and lower extremities, no evident muscle atrophy, no cyanosis, clubbing, or edema in her extremities, 4/5 grip strength bilaterally, and intact ability to manipulate a coin, pen, and cup without difficulty[.] ....On April 29, 2024, Nurse Clark advised that the claimant's migraines ‘are currently under control[.]... [Seth Fuhrman, PA-C] noted [on February 22, 2024, that] the claimant[ ] reported a return to baseline after her December 2023 fall and injury to her right knee..... Dr. Mastoor noted [on May 29, 2024,] that the claimant has no edema and has had further weight loss, down to 292 pounds. The claimant reported making diet changes (stopped drinking soda) and that she was trying to stay active. Dr. Mastoor found that the claimant presented with no edema and no rash.”). Tr. 25-26. The accuracy of this summary of the most recent medical evidence is corroborated by the ALJ’s corresponding exhibit citations. See id. at 828, 929, 935, 967, 981, 1036. As Nurse Hammon’s examination findings show that Poff retained erip strength and fine-motor control in her hands, and the most recent treatment evidence shows that Poff had marked improvement in areas effecting her ability to lift weight, use her feet, and tolerate environmental stimuli, ALJ Kauffman’s determination that Nurse Hammon’s findings on lifting, manipulation, and noise tolerance were 22 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 23 of 44 unpersuasive was anchored in the record. By citing that record evidence accordingly, the ALJ sufficiently built a bridge between the evidence and his result. Gamret, 994 F. Supp. 2d at 698; Jones, 364 F.3d at 505. And as the Court is obliged to review the totality of the decision when assessing the adequacy of an AlJ’s analysis, Jones, 364 F.3d at 505, ALJ Kauffman’s articulation of the medical evidence throughout the opinion does not warrant remand simply because that analysis was not reiterated in the specific section of the opinion deeming Nurse Hammon’s findings partially persuasive. Poffs contention that alternative evidence in the record supports and is consistent with Nurse Hammon’s opinion, and thus undermines ALJ Kauffman’s conclusion, is unavailing. In particular, Poff cites to findings from Nurse Hammon’s evaluation of Poff that she contends support all of Nurse Hammon’s limitation findings, including, among other things, that Poff had “plaque like rashes” over her body, tenderness in her knee joints and feet, and reduced 4/5 bilateral grip strength. Doc. 18 at 6-7. Poff also cites to findings from other medical evidence to support her contention that Nurse Hammon’s opinion limitations are consistent with the record, including evidence showing 23 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 24 of 44 that at various points in time Poff had rashes, tachycardia, back pain, leg pain, morbid obesity, and degenerative knee problems. Id. at 7—8. However, “[a] written evaluation of every piece of evidence is not required,” Phillips, 91 F. App’x at 780 n.7, “and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.” Consolo, 383 U.S. at 620. In essence, Poff asks the Court to reweigh the evidence in her favor here, but “[clourts are not permitted to re-weigh the evidence or impose their own factual determinations.” Chandler v. Comm’ of Soc. Sec., 667 F.3d 356, 359 (8d Cir. 2011). Because ALJ Kauffman assessed the weight of the evidence and cited to “such relevant evidence as a reasonable mind might accept as adequate to support” his conclusion concerning Nurse Hammon’s opinion, Pierce, 487 U.S. at 565, Poffs disagreement with that determination does not warrant remand. Rather, the ALJ’s evaluation is supported by substantial evidence in the record and is sufficiently articulated to permit judicial review, mandating affirmance. Gamret, 994 F. Supp. 2d at 698; Ficca, 901 F. 24 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 25 of 44 Supp. 2d at 5386 (“Factual findings which are supported by substantial evidence must be upheld.”). Finally, although Poff contends otherwise, the ALJ incorporated Nurse Hammon’s sitting, standing, and walking limitations into Poffs residual functional capacity. As the government correctly notes, see Doc. 15 at 7, ALJ Kauffman determined that Poff had the residual functional capacity to perform sedentary work, which limits an individual to walking and standing for no more than “2 hours of an 8-hour workday,” and sitting for “6 hours of an 8-hour workday.” Social Security Ruling §3-10, 19838 WL 31251, at *5 (1983). Nurse Hammon found, consistently, that Poff was limited to sitting for six hours and standing and walking for two hours in total during an eight-hour workday. Tr. 789. Additionally, Nurse Hammon’s findings that Poff can only sit for three hours at a time, stand for 30 minutes at a time, and walk for 15 minutes at a time, id., though not explicitly enumerated in Poff’s residual functional capacity, fall within the limitations restricting her to two hours of standing and walking, and six hours of sitting per workday. Thus, Nurse Hammon’s findings regarding Poff’s sitting, 25 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 26 of 44 standing, and walking limitations are reflected in Poff’s residual functional capacity. 2. Nurse Clark’s Opinion ALJ Kauffman’s opinion included an evaluation of four assessments that Nurse Clark completed concerning Poff's mental and physical functional abilities. ALJ Kauffman deemed all four assessment, which found marked limitations, unpersuasive. Tr. at 28— 29. Two of Nurse Clark’s assessments, conducted on January 9, 2024, and June 38, 2024, focused on Poff’s physical functional abilities and found, as summarized by ALJ Kauffman, that her symptoms would: [F]requently interfere with attention and concentration. She is unable to work in a competitive environment, even a sedentary occupation, on a full time basis. She can walk one block without rest. She can walk for 20-30 minutes at a time, stand for 20-[8]0 minutes at a time, and sit for 20-30 minutes at a time before needing to change position. She can sit, stand, and/or walk for a total of four hours in an eight-hour workday. She would need unscheduled breaks for 15-30 minutes for 75 minutes. The claimant has good days and bad days and would likely be absent from work about three times a month. She must use a cane or other assistive device while engaging in occasional standing/walking. She has significant limitations in performing repetitive reaching, handling, or fingering. She can lift and carry five pounds frequently and ten pounds occasionally. She can never carry more than ten pounds. On June 3, 2024, Nurse Clark again assessed the claimant’s functional abilities: her symptoms would often interfere with her attention and concentration. She would need to elevate 26 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 27 of 44 her legs four times during a normal workday. She can sit for 30 minutes at one time for a total of four hours in an eight- hour workday. She can stand or walk for 30 minutes at one time for a total of four hours each in an eight-hour workday. She would need unscheduled 15-380 minute breaks for 75 minutes during the workday. She can lift and carry less than ten pounds frequently and ten pounds occasionally. She can frequently balance. She can never stoop, kneel, and crouch. She can use her hands, fingers, and arms each for 50% of the workday. She would be absent from work more than four times a month|.] Tr. 29, 885-86. ALJ Koffman deemed those determinations unpersuasive on supportability and consistency grounds. First, the ALJ found that they were “not supported by Nurse Clark’s own physical examinations of the claimant,” which showed stable, normal findings. Id. at 28-29. ALJ Kauffman cited several exhibits in the record as a basis for his conclusion. Jd. A review of those exhibits reveals that from 2021 to 2024, Nurse Clark consistently found that Poff had a normal range of motion, normal breath, normal heart measures, normal skin, normal neurological findings, and a normal appearance. Jd. at 565-66, 575, 583-84, 617, 625, 633-34, 656, 706-07, 724, 737-38, 750-51, 760-61, 829-30, 838-39, 868, 873, 878, 960, 969—70, 978. 27 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 28 of 44 That evidence, however, contrasts with Nurse Clark’s determination that Poff suffered from significant limitations. Indeed, Nurse Clark found that Poff could reach, handle, or finger with her hands no more than 50% of the time, that she required a cane to walk, that she could not sit for more than 20-30 minutes at a time, and that she required unscheduled breaks every 75 minutes. Jd. at 883-86, 1021-22. Taken together, these severe restrictions might preclude Poff from performing even sedentary work. See Social Security Ruling 88-10, 1983 WL 31251, at *5 (1988) “Most unskilled sedentary jobs require good use of the hands and fingers for repetitive hand-finger actions.”). ALJ Kauffman, however, identified the significant contrast between Nurse Clark’s normal examination findings and severe assessment determination as the basis for his conclusion that the former failed to support the latter. Tr. 28 (“These findings are not supported by Nurse Clark’s own physical examinations of the claimant, showing overall stable, normal findings[.|”). As the ALJ cited the aforementioned record evidence, which supports his determination of discrepancies between Nurse Clark’s physical examination findings and her conclusions, his opinion contains a logical and accurate bridge 28 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 29 of 44 between the evidence and his conclusion. Gamret, 994 F. Supp. 2d at 698. Accordingly, ALJ Kauffman met his burden of articulation concerning the supportability factor. Second, the ALJ found that Nurse Clark’s physical assessments of Poff were “not consistent with medical evidence of record,” which showed improvement in Poff's symptoms with treatment, “including improvement in her psoriasis, lower extremity edema, knee pain, migraine headaches, and weight loss.” Tr. 28-29. Again, the ALJ cited several exhibits in the record as a basis for his conclusion, the contents of which support his determination. Jd. Namely, the cited medical evidence shows that Poff’s psoriasis cleared up with treatment (id. at 1036), Poff no longer had edema (id. at 981), Poffs right knee had returned to its baseline prior to a previous injury and that knee injections were providing additional relief as needed (id. at 929, 935), Poff's migraines were well under control, and she reportedly did not have very many (id. at 828, 967), and Poff had lost 85 pounds by watching her diet and staying active (id. at 981). Thus, the ALJ concluded that Poff's improvement and near cessation in certain symptoms contrasted with Nurse Clark’s work 29 Case 3:25-cv-00308-MWB -Document17_ Filed 01/13/26 Page 30 of 44 preclusive physical assessment findings. Specifically, Nurse Clark found that Poff had severely limited abilities in the areas of reaching, handling, fingering, walking, sitting, and staying on task, id. at 883-86, 1021-22; findings that might prove work preclusive. See Social Security Ruling 88-10, 1983 WL at *5. Again, ALJ Kauffman identified this discrepancy between Poff’s positive treatment evidence and Nurse Clark’s assessment findings as the basis for his finding of inconsistency. Id. at 28 (“They are also not consistent with medical evidence of record, showing improvement in her symptoms with treatment, including improvement in her psoriasis, lower extremity edema, knee pain, migraine headaches, and weight loss.”). As his comparison between the treatment evidence and assessment findings was accurate and logically bridged any gap between the evidence and the result, ALJ Kauffman met his burden of articulation. Gamret, 994 F. Supp. 2d at 698; Jones, 364 F.3d at 505. Poff cites other medical evidence supporting her contention that Nurse Clark’s physical limitation findings were consistent with the record, including records showing that at various times Poff had rashes, tachycardia, back pain, leg pain, morbid obesity, and degenerative knee 30 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 31 of 44 problems. Jd. at 11. But “[a] written evaluation of every piece of evidence is not required,” Phillips, 91 F. App’x at 780 n.7, “and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.” Consolo, 383 U.S. at 620. Thus, because ALJ Kauffman assessed the weight of the evidence and cited to “such relevant evidence as a reasonable mind might accept as adequate to support[]” his conclusion concerning the inconsistency of Nurse Clark’s physical assessments, Poff’s disagreement with that determination does not warrant remand. Pierce, 487 U.S. at 565. Nurse Clark’s remaining two assessments of Poff, also conducted on January 9, 2024, and June 8, 2024, focused on her mental functional abilities and found, as summarized by ALJ Kauffman, that her symptoms caused: [M]arked (serious limitation in the area and cannot generally be performed satisfactorily) limitation in her ability to maintain attention and concentration for extended periods of time. She has a moderate (intermittent difficulty performing in the area and cannot “always” be performed satisfactorily) limitation in her ability to understand and remember short and simple instructions, perform activities on schedule and maintain regular attendance, complete a normal workweek and workday without interruptions, and perform at a consistent pace with a standard number and length of breaks. 31 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 32 of 44 She has a minimal (mild limitation but can generally function satisfactorily) limitation in her ability to understand and remember detailed instructions, perform simple and detailed instructions, sustain an ordinary routine without special supervision, and make simple work-related decisions. She has no limitation in terms of social interaction. She would be expected to be off-task 15-20% of the workday due to psychologically based symptoms. On June 38, 2024, Nurse Clark again assessed the claimant's mental functional abilities. She found that the claimant’s abilities and limitations remained unchanged compared to her prior January 2024 opinion, as noted above|.| Id. at 28, 887-88. ALJ Koffman again deemed those determinations unpersuasive on supportability and consistency grounds. First, the ALJ found that they were “not supported by Nurse Clark’s treatment notes,” which “showed overall stable, normal findings[.]” Tr. 28-29. A review of the exhibits ALJ Kauffman cited in reaching that conclusion identifies supporting evidence. Namely, findings from Nurse Clark’s mental examinations demonstrate that from 2021 to 2024, she consistently found that Poff had a normal mood, normal behavior, normal thought content, and normal judgment. Id. at 565-66, 634, 738, 751, 829-30, 868, 873, 878, 970. By contrast, Nurse Clark concluded that Poff had marked deficits in the areas of sustaining concentration and attention. Id. at 28. Nurse 32 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 33 of 44 Clark found that Poff had serious limitations in her ability to concentrate and maintain attention for extended periods, and that these limitations, coupled with additional limitations in the areas of understanding and memory, would cause her to be off task 15-20% of the time and render it moderately difficult for her to finish workdays and workweeks without interruption. Tr. 887-88, 1024—25. The disruptive effect these limitations would have on Poff’s ability to meet the demands of a consistent, full time work schedule would potentially preclude her employment in even sedentary positions. See Social Security Ruling 96-9p, 1996 WL 3741885, at *9 (1996) (“A substantial loss of ability to meet any one of several basic work-related activities on a sustained basis (i.e., 8 hours a day, 5 days a week, or an equivalent work schedule), will substantially erode the unskilled sedentary occupational base and would justify a finding of disability.”). ALJ Kauffman, however, contrasted the severity of Nurse Clark’s assessment with her examination findings as his basis for finding the former unsupported by the latter. Tr. 28-29 (“These findings are not supported by Nurse Clark’s treatment notes, showing overall stable, normal findings[.]”). As this comparison between the treatment 33 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 34 of 44 evidence and assessment findings is supported in the record and logically bridges any gap from the evidence to the result, ALJ Kauffman met his burden of articulation. Gamret, 994 F. Supp. 2d at 698; Jones, 364 F.3d at 505. Second, the ALJ found that Nurse Clark’s mental assessments of Poff were “not consistent” with examination evidence that “noted improvement in her symptoms with starting Zoloft and... normal mental status... findings... .” Tr. 29. Again, a review of the exhibits ALJ Kauffman cited in reaching that conclusion identifies supporting evidence. Namely, examinations of Poff from 2023 and 2024 by Nurse Clark and consultative examiner Kathleen Lederman revealed that Poff had a regular affect and mood, fully intact attention, fully intact concentration, fully intact memory, average intellectual functioning, good insight, and good judgment, in addition to having controlled symptoms of anxiety and depression once re-prescribed Zoloft. Id. at 851-52, 867-68, 872-78, 876-77, 968. By contrast, Nurse Clark found that Poff had serious limitations in her ability to concentrate and maintain attention for extended periods. Id. at 887-88, 1024-25. When coupled with Nurse Clark’s other 34 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 35 of 44 findings that Poff would have moderate difficulty meeting the demands of a consistent, full time work schedule, Poff might be precluded from employment in even sedentary positions. See Social Security Ruling 96- 9p, 1996 WL at *9 (“A substantial loss of ability to meet any one of several basic work-related activities on a sustained basis (i.e:, 8 hours a day, 5 days a week, or an equivalent work schedule), will substantially erode the unskilled sedentary occupational base and would justify a finding of disability.”). ALJ Kauffman, however, contrasted the severity of Nurse Clark’s evaluation with the examination findings by both Nurse Clark and Kathleen Lederman as his basis for finding the former inconsistent with the latter. Tr. 28-29 (“They are also not consistent with the claimant’s noted improvement in her symptoms with starting Zoloft and her normal mental status examination findings per her consultative evaluation, as noted above [.]”). As this comparison between the examination evidence and assessment findings is supported in the record and logically bridges any gap from the evidence to the result, ALJ Kauffman again met his burden of articulation. Gamret, 994 F. Supp. 2d at 698; Jones, 364 F.3d at 505. 35 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 36 of 44 Although Poff contends that ALJ Kauffman failed to consider record evidence that allegedly supports and is consistent with Nurse Clark’s mental assessments, a review of the ALJ’s opinion concludes otherwise. In particular, Poff contends that ALJ Kauffman failed to consider evidence of Poff's chronic pain, heavy medication regimen, side effects from the medication regimen, indication that Poff’s “conditions improved in the context of her stopping work[,|” and fibromyalgia. Doc. 13 at 10-11. As set forth above, however, the ALJ did specifically discuss most of this evidence in his opinion, albeit in sections distinct from his evaluation of Nurse Clark’s persuasiveness. For example, the ALJ noted: On April 6, 2028, Nurse Clark performed the claimant’s annual physical examination. She noted that the claimant reported getting relief [from her pain] with medical marijuana. The claimant also complained of memory issues and headaches with stopping oxycontin. The claimant reported having migraines more often but did not want to increase her amitriptyline dose. ... On October 16, 2028, Nurse Clark examined the claimant. She noted the claimant reported not having ‘very many migraines at all, maybe little headaches.’ The claimant reported that her migraines were due to stress from her last relationship and difficulty sleeping. The claimant reported ongoing pain but did not want to make any medication changes but had increased her medical marijuana. 36 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 37 of 44 Tr. 23-25. As the Court considers the ALJ’s opinion as a whole, Jones, 364 F.3d at 505, the location in which ALJ Kauffman addressed treatment evidence does not detract from his conclusion. Moreover, “[a] written evaluation of every piece of evidence is not required, as long as the ALJ articulates at some minimum level her analysis of a particular line of evidence.” Phillips, 91 F. App’x at 780 n.7 Ganternal citation omitted). Here, ALJ Kauffman sufficiently articulated his analysis of the evidence concerning Nurse Clark’s examinations of Poff. See Tr. 23-25. Requiring him to address every factor that Poff now advances in her favor goes beyond the applicable standard. Moreover, the evidence that Poff protests went unmentioned—two discrete findings by Nurse Clark indicating that work cessation may have contributed to improvement in two of Poff’s conditions—does not create erounds for remand, as “the ALJ’s mere failure to cite specific evidence does not establish that the ALJ failed to consider it.” Phillips, 91 F. App’x 780 n.7. Accordingly, ALJ Kauffman reasonably articulated his determination that Nurse Clark’s opinions were unpersuasive, on both supportability and consistency grounds. That conclusion, supported by 37 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 38 of 44 substantial cited evidence, permits meaningful judicial review and should be affirmed. C. The ALJ’s Evaluation of Poff's Subjective Symptom Complaints Poff contends that ALJ Kauffman erred in his evaluation of her subjective symptom complaints, by focusing too heavily on their improvement with treatment. Doc. 13 at 14. As set forth below, the ALJ’s evaluation of the consistency of Poffs alleged symptoms against the objective evidence complied with his regulatory duty and was supported by substantial evidence. “Allegations of pain and other subjective symptoms must be supported by objective medical evidence.” Hartranft v. Apfel, 181 F.3d 358, 362 (3d Cir. 1999) (citing 20 C.F.R. § 404.1529). Thus, when a claimant’s statements about the severity of her impairment are not well-grounded in the objective medical evidence, but the underlying impairment “could reasonably be expected to produce” the complained of pain or symptoms, the “ALJ must make a finding on the credibility of the individual’s statements based on a consideration of the entire case record.” McKean v. Colvin, 150 F. Supp. 3d 406, 415-16 (M.D. Pa. 2015). 38 Case 3:25-cv-00308-MWB Document1i7_ Filed 01/13/26 Page 39 of 44 To this end, ALJs are required to consider all alleged symptoms and the extent to which such symptoms are reasonably consistent with the objective medical and other evidence. 20 C.F.R. §§ 404.1529(a), 416.929(a). The regulations require objective medical evidence from an acceptable medical source showing the presence of an impairment that could reasonably be expected to produce the symptoms alleged and that, when considered with all the other evidence, would lead to a disability determination. Id. When evaluating a claimant’s symptoms, the ALJ must follow a two-step process to (1) ascertain whether the claimant has a medically determinable impairment that could reasonably be expected to produce the claimant’s alleged symptoms, and (2) evaluate the intensity and persistence of the claimant’s symptoms such as pain and determine the extent to which they limit the ability to perform work-related activities. Social Security Ruling 16-8p, 2017 WL 518304, at *3—4 (2017). ALJ Kauffman properly followed this two-step process and sufficiently compared Poff’s alleged symptoms to the objective medical evidence. First, he concluded that Poff’s “medically determinable impairments could reasonably be expected to cause” her alleged 39 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 40 of 44 symptoms. Tr. 23. In reaching this determination, ALJ Kauffman found that the record, including treatment records and examinations, established Poff's degenerative joint disease of the right knee, degenerative disc disease of the lumbar spine, migraine headaches, obesity, psoriatic arthritis, fibromyalgia, and tachycardia. Tr. 20, 23-26. The nature of these severe impairments, coupled with Poff's symptom testimony about feeling lightheaded and dizzy at times, and having impediments in her ability to squat, bend, kneel, climb stairs, lift, stand, reach, walk, sit, use her hands, concentrate, and handle changes in weather, led ALJ Kauffman to find that the latter could reasonably cause the former. Id. at 23. At the second step of the process, however, ALJ Kauffman concluded that Poff’s “statements concerning the intensity, persistence and limiting effects of these symptoms are not entirely consistent with the medical evidence and other evidence in the record... .” Id. at 28. The ALJ found that the evidence showed Poff’s symptoms significantly improved or disappeared completely with treatment. Id. at 29. In support of that determination, ALJ Kauffman highlighted recent examination evidence showing that: Poff’s palpitations and lower 40 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 41 of 44 extremity edema improved with medication; Poff denied chest pains or palpations during a May 2024 medical exam, and was noted to have lost a significant amount of weight through watching her diet and activity; she no longer had edema or a rash; she testified at the hearing with the ALJ that she recently lost more weight; she had not sought any orthopedic treatment for her lower back, and her other alleged sources of chronic pain, including fibromyalgia, were managed through primary care treatment; her migraines were reportedly well under control; and symptoms related to her right knee injury saw recent improvement with injections. Jd. at 29. ALJ Kauffman specifically and accurately cited to the medical records corroborating those factors, including multiple cardiology visits (id. at 471, 981, 985), hearing testimony (id. at 66), emergency department records (id. at 460-65), primary care appointment records from 2021 to 2024 (id. at 553-765, 827-46, 866— 81, 955-80), and orthopedic treatment records (id. at 929). Based on that substantial body of evidence, the ALJ deemed Poff’s more severe symptom allegations inconsistent with the record, and thus non-credible. Jd. That analysis of the evidence met ALJ Kauffiman’s regulatory duty to evaluate the intensity and persistence of Poff’s 41 Case 3:25-cv-00308-MWB Document17_ Filed 01/13/26 Page 42 of 44 symptoms against the evidence to determine the extent to which they actually limited her work-related abilities. See 20 C.F.R. §§ 404.1529(a), 416.929(a); Phillips, 91 F. App’x at 780 (“[A] claimant must show that _the impairment resulted in disabling limitations.”). In opposition to the ALJ’s credibility determination, Poff contends that the “mere improvement of symptoms alone does not disprove... subjective allegations of disabling symptoms.” Doc. 18 at 15. This contention, however, misapprehends the burden of persuasion concerning subjective symptom allegations. A claimant’s statements regarding subjective symptoms are not, by default, considered credible; rather, “[alllegations of pain and other subjective symptoms must be supported by objective medical evidence.” Hartranft, 181 F.3d at 362 (citing 20 C.F.R. § 404.1529). Here, the ALJ assessed that objective medical evidence and deemed it inconsistent with Poff’s symptom allegations, because the evidence showed that the severity of Poff's symptoms had significantly abated with recent treatments. See Tr. 29. Thus, pursuant to his weighing of the evidence, ALJ Kauffman concluded that Poff’s subjective symptom allegations were not credible; a determination 42 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 43 of 44 entitled to significant deference. See Diaz, 577 F.3d at 506 (In determining whether there is substantial evidence to support an administrative law judge’s decision, we owe deference to his evaluation of the evidence [and] assessment of the credibility of witnesses ... .”). Accordingly, ALJ Kauffman complied with his regulatory duty in evaluating Poffs symptom allegations, and his conclusion that her allegations were not credible was supported by substantial evidence. IV. Recommendation For the forgoing reasons, IT IS RECOMMENDED that the district court AFFIRM the Commissioner’s decision, direct that judgment be entered in favor of the defendant, and instruct the clerk to close this case. The parties are further placed on notice that pursuant to Local Rule 72.3: Any party may object to a magistrate judge’s proposed findings, recommendations or report addressing a motion or matter described in 28 U.S.C. § 636 (b)(1)(B) or making a recommendation for the disposition of a prisoner case or a habeas corpus petition within fourteen (14) days after being served with a copy thereof. Such party shall file with the clerk of court, and serve on the magistrate judge and all parties, written objections which shall specifically identify the portions of the proposed findings, recommendations or report to which objection is made and the basis for such objections. The briefing requirements set forth in Local Rule 72.2 shall apply. A judge shall make a de novo determination of those 43 Case 3:25-cv-00308-MWB Document17 _ Filed 01/13/26 Page 44 of 44 portions of the report or specified proposed findings or recommendations to which objection is made and may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge. The judge, however, need conduct a new hearing only in his or her discretion or where required by law, and may consider the record developed before the magistrate judge, making his or her own determination on the basis of that record. The judge may also receive further evidence, recall witnesses or recommit the matter to the magistrate judge with instructions. The failure to file timely objections to the foregoing Report and Recommendation may constitute a waiver of any appellate rights. Date: January 13, 2026 s/ Phillip J. Caraballo Phillip J. Caraballo United States Magistrate Judge 44
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