Hayes v. Commissioner of Social Security

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

FORT WAYNE DIVISION

ROCHELLE HAYES,

Plaintiff,

v. Case No. 1:24-CV-184 JD

COMMISSIONER OF SOCIAL

SECURITY,

Defendant.

OPINION AND ORDER

Plaintiff Rochelle Hayes applied for disability insurance benefits under Title II and Title

XVI of the Social Security Act, alleging that she became disabled in December 2019. Ms.

Hayes’s claims were rejected, leading to a review by an Administrative Law Judge (“ALJ”), who

concluded that she was not disabled. The Appeals Council later denied her request for review,

and Ms. Hayes now seeks judicial review in this Court. For the reasons below, the Court will

remand the case to the Social Security Administration for further proceedings.

A. Standard of Review

Because the Appeals Council denied review, the Court evaluates the ALJ’s decision as

the final word of the Commissioner of Social Security. Schomas v. Colvin, 732 F.3d 702, 707

(7th Cir. 2013). This Court will affirm the Commissioner’s findings of fact and denial of benefits

if they are supported by substantial evidence. Craft v. Astrue, 539 F.3d 668, 673 (7th Cir. 2008).

Substantial evidence consists of “such relevant evidence as a reasonable mind might accept as

adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971). “The

threshold for substantial evidence ‘is not high.’” Warnell v. O’Malley, 97 F.4th 1050, 1052 (7th

Cir. 2024) (quoting Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019)). This evidence must be

“more than a scintilla but may be less than a preponderance.” Skinner v. Astrue, 478 F.3d 836,

841 (7th Cir. 2007). Even if “reasonable minds could differ” about the disability status of the

claimant, the Court must affirm the Commissioner’s decision as long as it is adequately

supported. Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008).

The ALJ has the duty to weigh the evidence, resolve material conflicts, make

independent findings of fact, and dispose of the case accordingly. Perales, 402 U.S. at 399–400.

In evaluating the ALJ’s decision, the Court considers the entire administrative record but does

not reweigh evidence, resolve conflicts, decide questions of credibility, or substitute the Court’s

own judgment for that of the Commissioner. Lopez ex rel. Lopez v. Barnhart, 336 F.3d 535, 539

(7th Cir. 2003). Still the Court conducts a “critical review of the evidence” before affirming the

Commissioner’s decision. Id. An ALJ must evaluate both the evidence favoring the claimant and

the evidence favoring the claim’s rejection and may not ignore an entire line of evidence that is

contrary to his or her findings. Zurawski v. Halter, 245 F.3d 881, 887 (7th Cir. 2001). The ALJ

must provide a “logical bridge” between the evidence and the conclusions. Terry v. Astrue, 580

F.3d 471, 475 (7th Cir. 2009).

B. Standard for Disability

Disability benefits are available only to those individuals who can establish disability

under the Social Security Act. Estok v. Apfel, 152 F.3d 636, 638 (7th Cir. 1998). The claimant

must be unable “to engage in any substantial gainful activity by reason of any medically

determinable physical or mental impairment which can be expected to result in death or which

has lasted or can be expected to last for a continuous period of not less than 12 months.” 42

U.S.C. § 423(d)(1)(A). The Social Security regulations create a five-step process to determine

whether the claimant qualifies as disabled. 20 C.F.R. §§ 404.1520(a)(4)(i)–(v); 416.920(a)(4)(i)–

(v). The steps are to be used in the following order:

1. Whether the claimant is currently engaged in substantial gainful activity;

2. Whether the claimant has a medically severe impairment;

3. Whether the claimant’s impairment meets or equals one listed in the regulations;

4. Whether the claimant can still perform past relevant work; and

5. Whether the claimant can perform other work in the national economy.

See Dixon v. Massanari, 270 F.3d 1171, 1176 (7th Cir. 2001).

At step two, an impairment is severe if it significantly limits a claimant’s ability to do

basic work activities. 20 C.F.R. §§ 404.1522(a), 416.922(a). At step three, a claimant is deemed

disabled if the ALJ determines that the claimant’s impairment or combination of impairments

meets or equals an impairment listed in the regulations. 20 C.F.R. §§ 404.1520(a)(4)(iii),

416.920(a)(4)(iii). If not, the ALJ must then assess the claimant’s residual functional capacity,

which is defined as the most a person can do despite any physical and mental limitations that

may affect what can be done in a work setting. 20 C.F.R. §§ 404.1545, 416.945. The ALJ uses

the residual functional capacity to determine whether the claimant can perform his or her past

work under step four and whether the claimant can perform other work in society at step five. 20

C.F.R. §§404.1520(e), 416.920(e). A claimant qualifies as disabled if he or she cannot perform

such work. The claimant has the initial burden of proof at steps one through four, while the

burden shifts to the Commissioner at step five to show that there are a significant number of jobs

in the national economy that the claimant can perform. Young v. Barnhart, 362 F.3d 995, 1000

(7th Cir. 2004).

C. Discussion

(1) The ALJ’s Decision

Ms. Hayes filed a Title II and Title XVI application for disability insurance benefits

alleging disability beginning December 2020. Her claim was denied initially and upon

reconsideration, leading to a hearing before an ALJ on August 10, 2023.

At the hearing, Ms. Hayes claimed, among other things, that due to her lumbar and knee

issues, driving is very difficult for her, and she finds it hard to sit in a car or drive. (R. at 54.) She

described her typical day as increasingly challenging, with difficulty walking from her room to

the bathroom and needing assistance to get off the toilet. (R. at 59.) Ms. Hayes told the ALJ she

can sit in a chair for only 10 to 15 minutes before needing to change positions. (R. at 59–60.) She

has to use a scooter at the grocery store as she can stand for only about 15 minutes. (R. at 60.)

She said she can lift no more than a pound without hurting herself. (Id.) She uses a knee brace

for stability and sometimes relies on her fiancé for support. (R. at 61.) Recently she had been

using a cane five to six times a day because of fear of falling. (R. at 67.) She has a shower chair

and sometimes requires her fiancé’s help to wash herself. (R. at 66.)

On September 21, 2023, the ALJ issued a decision finding that Ms. Hayes was not

disabled. (R. at 33.) In doing so, the ALJ employed the customary five-step analysis. At Step 2,

the ALJ determined that Ms. Hayes suffered from the following severe impairments: “panic

disorder with agoraphobia, major depressive disorder single episode severe without psychotic

features, post-traumatic stress disorder, type 2 diabetes, degenerative lumbar spinal stenosis, L5

right radiculopathy, complex tear of the lateral meniscus, and obesity.” (R. at 26.)

At Step 4, the ALJ determined Ms. Hayes’s residual functional capacity (“RFC”),1

finding that she can

perform light work2 . . . except she can frequently climb ramps, stairs, ladders,

ropes, and scaffolds. She can frequently crawl. The claimant must avoid

concentrated exposure to wetness and workplace hazards including dangerous

machinery, moving mechanical parts, and unprotected heights. She can understand,

carry out, and remember simple instructions. She is able to make judgments

commensurate with functions of simple, repetitive tasks. She is limited to

occasional contact with supervisors, coworkers, and the public. She is able to deal

with frequent changes in a routine work setting.

(R. at 28.)

In light of this RFC, the ALJ determined that there are jobs in significant numbers in the

national economy that Ms. Hayes can perform (housekeeper, inspector/hand packager, and

routing clerk). (R. at 36.) The ALJ arrived at this conclusion after questioning a vocational expert

(“VE”) at the hearing.3

In her decision, the ALJ recognized that Ms. Hayes did suffer from neck, low back, and

leg pain, but found that clinical evaluations showed few deficits as a result of those conditions.

The ALJ noted that, in late 2019, Ms. Hayes received chiropractic treatment for low back and

neck pain and visited the emergency department with worsening back pain. However, despite

1 “The RFC reflects ‘the most [a person] can still do despite [the] limitations’ caused by medically

determinable impairments and is assessed ‘based on all the relevant evidence in [the] case record.’” Cervantes v.

Kijakazi, No. 20-3334, 2021 WL 6101361, at *2 (7th Cir. Dec. 21, 2021) (quoting 20 C.F.R. §§ 404.1545,

416.945(a)).

2 “Light work involves lifting no more than 20 pounds at a time with frequent lifting or carrying of objects

weighing up to 10 pounds. Even though the weight lifted may be very little, a job is in this category when it requires

a good deal of walking or standing, or when it involves sitting most of the time with some pushing and pulling of

arm or leg controls. To be considered capable of performing a full or wide range of light work, you must have the

ability to do substantially all of these activities. If someone can do light work, we determine that he or she can also

do sedentary work, unless there are additional limiting factors such as loss of fine dexterity or inability to sit for long

periods of time.” 20 C.F.R. § 404.1567.

3 Although the vocation expert stated that a hypothetical person with Ms. Hayes’s RFC could perform those

jobs, she testified that no job opportunities would remain for an individual needing to elevate her legs to waist height

for at least thirty minutes during the workday, exclusive of breaks and mealtimes. (R. at 71–72.)

positive straight leg raising and spinal tenderness, she exhibited normal strength, sensation, and

reflexes. (R. at 29.) In early 2020, Ms. Hayes experienced low back pain radiating to her legs,

limited lower extremity function, and hypoactive reflexes, but intact sensation. (Id.) She

underwent lumbar spine surgery in March 2022, but post-surgery, she had intact motor function

and sensation, and walked with a steady gait. (R. at 30.) In August 2022, Ms. Hayes had surgery

to repair a left knee meniscus tear and attended physical therapy. She experienced ongoing

swelling and pain affecting her gait mechanics and standing. By December 2022, Ms. Hayes

reported popping and clicking in her left knee and pain extending to her left hip, yet the knee was

stable, and she was bearing full weight. (Id.)

In evaluating the medical opinions, the ALJ reviewed Exhibit 8F, as well as the opinions

of a physical therapist and state agency medical consultants. She also examined a check-marked

form from a medical provider she could not identify.

Exhibit 8F is a sixty-six-page document containing multiple physical therapy notes and

two assessments by Physician Assistant (“PA”) Laniel Cua. The ALJ rejected the medical

findings in Exhibit 8F as unpersuasive:

The record contained numerous notes of short-term limitations (8F). The

undersigned finds such assessments unpersuasive because the limitations applied

for only limited periods and did not consider the claimant’s ongoing functioning.

(R. at 31.)

The ALJ also reviewed a 2021 functional capacity evaluation but found it unpersuasive

because the evaluator rated its validity at only 23%:

The claimant had a functional capacity evaluation in May 2021 where she was

observed entering the facility with a normal gait and she said with no signs of

distress. She described substantial pain that appeared out of proportion and the

functional capacity evaluation was deemed to be only 23% valid. Accordingly, the

undersigned does not find the functional capacity evaluation findings persuasive.

IO III I OS IE III SEE IIE II SID II Oe

(/d. (citations to the record omitted).)

Next, the ALJ found the assessments of the state agency medical consultants persuasive,

noting that they reviewed the record thoroughly and that the evidence as a whole supported their

conclusions:

State Agency medical consultants found that the claimant could perform light work

with frequently crawling and climbing ramps, stairs, ladders, ropes, or scaffolds.

The consultants noted that the claimant had to avoid concentrated exposure to

wetness and hazards. The undersigned finds such assessments persuasive in

general. The consultants reviewed the record and based their conclusions on the

findings therein. Moreover, the evidence as a whole confirmed that despite her

physical conditions and pain, she could perform a reduced range of light work

consistent with the consultants’ opinions.

Finally, the ALJ was unpersuaded by a medical opinion in the form with an illegible

signature:

A form with an illegible signature indicated that the claimant could occasionally

lift ten pounds to the waist, fifteen pounds to the shoulders and overhead, carry ten

pounds, and push/pull five pounds. The form indicated occasional squatting,

kneeling, and crawling with never stooping, bending, balancing, or climbing. The

undersigned finds such opinion unpersuasive because it was unclear who signed

such form. Moreover, the evidence as a whole failed to document such significant

functional limitations. Indeed, while she had ongoing knee and back pain, such

conditions improved to some degree with treatment. She had some strength deficits

in her left leg and an antalgic gait, but generally normal strength otherwise and she

continued to ambulate independently.

(R. at 31-32 (citations to the record omitted).) This form has a header of “Physical Medicine

Consultants” and is signed on June 6, 2021, but the signature has all the mystery of a doctor’s

prescription pad:

Disease workWay = 8 howrs wi breaks

er

Date; eel moni IG

Elsewhere in the record, a medical order issued by Dr. Thomas Lazoff shows his association

with “Physical Medicine Consultants.” The medical order is signed by Dr. Lazoff but that

signature differs from the signature on the medical form issued on June 1, 2021:

cect MOTRIN

□□□

[yar

SORT OLE BI

(Medical Order, R. at 878.) A treatment note from Fort Wayne Orthopedics (dated October 7,

2021) states that Ms. Hayes “was seeing Dr. Lazoff (Physician Medical Consultants) initially

after her work injury . . . and was referred here by her PCP. Dr. Lazoff had cleared her to return

to work with restrictions.” (Patient Clinical Interview, R. at 1075.)

In summary, the ALJ found that Ms. Hayes’s alleged symptoms and limitations were

only partially consistent with the evidence because despite her “ongoing back and knee pain” and

“some instances of decreased strength in her left lower extremity,” she had “otherwise normal

strength in her extremities and she was able to [walk] independently” as well “[t]he evidence as a

whole established that she could perform a reduced range of light work... .” (R. at 32)

(2) Medical Opinions

In her appeal, Ms. Hayes argues that the ALJ committed three reversible errors.

According to Ms. Hayes, the ALJ disregarded her use of a cane; failed to properly consider her

subjective allegations; and failed to consider as required by the agency’s regulations the

supportability and consistency of the opinion bearing illegible signature and the opinion of PA

Cua. Of all the arguments, the last one is most substantive and warrants remand for further

consideration. As a result, the Court will address this argument, declining to reach the remaining

ones, leaving them to be resolved upon remand if necessary.

Under the regulations, an ALJ does “not defer or give any specific evidentiary weight,

including controlling weight, to any medical opinion(s) or prior administrative medical

finding(s), including those from [a claimant’s] medical sources.” 20 C.F.R. § 404.1520c(a). The

ALJ must explain “how persuasive [she] find[s] all of the medical opinions and all of the prior

administrative medical findings in [a claimant’s] case record.” 20 C.F.R. § 404.1520c(b). When

considering the persuasiveness of any medical opinion, an ALJ must consider the following

factors: supportability; consistency; relationship with the claimant, including the length of the

treatment relationship, frequency of examination, purpose of the treatment relationship, extent of

the treatment relationship, and examining relations; specialization; and any other factors that

tend to support the medical opinion, including evidence that the medical source is familiar with

other medical evidence or has an understanding of social security policies. 20 C.F.R. §§

404.1520(c), 416.920c(c). Supportability and consistency are the two most important factors. 20

C.F.R. § 404.1520c(a). These are the factors the ALJ must explicitly discuss, even though the

ALJ need only consider the other factors. 20 C.F.R. § 404.1520c(b). Failure to adequately

discuss supportability and consistency requires remand. See Tammy M. v. Saul, 2021 WL

2451907, at *7–8 (N.D. Ind. June 16, 2021). The more consistent the medical opinion is “with

the evidence from other medical sources and nonmedical sources in the claim, the more

persuasive” the medical opinion will be. 20 C.F.R. § 404.1520c(c)(2). For a provider’s opinion to

be supportable, it must be based on “objective medical evidence and supporting explanations.”

20 C.F.R. § 404.1520c(c)(1). “The more relevant the objective medical evidence and supporting

explanations presented by a medical 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).

The ALJ considered four medical opinions in her written decision:

• the opinions of two agency consultants, Dr. Sands and Dr. Corcoran, who reviewed Ms.

Hayes’s medical records, and whom she found to be persuasive;

• the opinion of a physical therapist, who found the functional capacity evaluation to be

only 23% valid—a factor that led the ALJ to discount its conclusions; and

• a medical opinion bearing an illegible signature, which the ALJ discounted due to

uncertainty about its authorship and because it conflicted “with the evidence as a whole.”

(R. at 31.)

The ALJ did not consider PA Cua’s medical opinion, dismissing it as part of “numerous

notes of short-term limitations” found in Exhibit 8F. (See id.) The Court begins its analysis with

this rejection.

PA Cua authored two medical opinions when filling out an Activity Prescription Form on

behalf of Ms. Hayes.4 On January 22, 2020, PA Cua issued a list of limitations for Ms. Hayes’s

work for the period of March 16 through April 7, 2020. PA Cua limited Ms. Hayes’s ability to

stand and walk one to three hours per day. She also opined that Ms. Hayes should seldomly (0–1

hour daily) climb stairs, twist, bend, or stoop; Ms. Hayes should never perform work from a

ladder, climb ladders, or crawl; Ms. Hayes was also restricted to occasional lifting, carrying,

pushing, and pulling five pounds. (R. at 825.)

4 Activity Prescription Form is a form used in Washington State “to communicate the worker’s: ability to

work, functional capacities, physical restrictions, and treatment plan.” Washington State Department of Labor &

Industries, https://perma.cc/V4WJ-N25Y (last visited May 30, 2025).

On April 9, 2020, PA Cua filled out another Activity Prescription Form, applicable

between April 9 and May 20, 2020. On the form, she noted the same limitations as on the

previous form in Ms. Hayes’s ability to stand, walk, twist, bend, stoop, squat, kneel, climb stairs,

lift, carry, push and pull five pounds. She added, however, that Ms. Hayes should be allowed to

alternate between standing and sitting. (R. at 827.)

The Commissioner does not dispute that PA Cua’s limitations constitute medical

opinions. Instead, the Commissioner offers a one-sentence argument—unsupported by any

citation to case law, federal regulations, or other authority—asserting that the opinions are

irrelevant because they do not address Ms. Hayes’s functioning over a period of at least twelve

consecutive months, as required for a disability finding. (Def.’s Br., DE 13 at 7.) This argument

amounts to the Commissioner’s post-hoc justification for an administrative decision that was not

articulated by the ALJ, who found the opinions unpersuasive because the limitations applied to

short-term periods. Such additional arguments are impermissible under the Chenery doctrine,

which requires that the agency’s decision be judged solely on the grounds articulated by the

agency itself at the time of the decision. See SEC v. Chenery Corp., 318 U.S. 80, 93–95 (1943);

Spiva v. Astrue, 628 F.3d 346, 353 (7th Cir. 2010). Courts in the Seventh Circuit have

consistently rejected post-hoc rationalizations, emphasizing that the ALJ must build an accurate

and logical bridge between the evidence and her conclusions, and that reviewing courts cannot

affirm decisions based on arguments or reasoning not provided by the ALJ. See Parker v. Astrue,

597 F.3d 920, 922 (7th Cir. 2010) (describing how the Chenery doctrine “forbids an agency’s

lawyers to defend the agency’s decision on grounds that the agency itself had not embraced”

(citations omitted)).

But in any case, ALJs aren’t limited to considering medical opinions that cover a period

of least one year. Indeed, no time limitations are imposed in the Agency’s own regulations:

When a medical source provides one or more medical opinions or prior

administrative medical findings, we will consider those medical opinions or prior

administrative medical findings from that medical source together using the factors

listed in paragraphs (c)(1) through (c)(5) of this section, as appropriate.

20 C.F.R. § 404.1520c(a). While a medical opinion covering only a short period may

indeed raise questions about supportability or consistency, the ALJ did not address either factor.

Instead, she dismissed PA Cua’s opinions solely because they did not span a full year, deeming

them irrelevant. But if the ALJ believed that PA Cua’s opinions were irrelevant, she needed to

provide a reason, a logical bridge from the evidence to conclusion, that the Court could follow.

Absent that bridge, the ALJ decision to discount PA Cua is not based on substantial evidence.

See Colson v. Colvin, 120 F. Supp. 3d 778, 789 (N.D. Ill. 2015) (“Although an ALJ is not

required to discuss every piece of evidence, he must consider all of the evidence that is relevant

to the disability determination and provide enough analysis in his decision to permit meaningful

judicial review.”).5

Next, the Court turns to the medical opinion with an illegible signature. The opinion

states that Ms. Hayes could occasionally squat; kneel; crawl; push or pull five pounds; lift ten

pounds from floor to waist; fifteen pounds from waist to shoulder; and fifteen pounds from

shoulder to overhead. In addition, it states that Ms. Hayes should never stoop, bend, balance,

climb, or be exposed to unprotected heights. (R. at 1114.) The ALJ rejected this opinion on the

5 “The ALJ must also ‘consider the combined effect of all of [the claimant’s] impairments without regard to

whether any such impairment, if considered separately, would be of sufficient severity.’ See 20 C.F.R. § 416.923.

The ALJ is required to undertake this analysis because the combination of a claimant’s impairments ‘might well be

totally disabling’ even if each of the claimant’s impairments standing alone is not serious.” Colson v. Colvin, 120 F.

Supp. 3d 778, 789–90 (N.D. Ill. 2015) (quoting Martinez v. Astrue, 630 F.3d 693, 698 (7th Cir. 2011)). The ALJ

made no such analysis here.

grounds that the signatory was unidentified and that “the evidence as a whole failed to document

. . . significant functional limitations” as described in the opinion. The Court finds that this

reasoning is insufficient and concludes that it constitutes legal error requiring remand.

Although the primary responsibility for producing medical evidence remains with the

plaintiff, “[a]n ALJ [has] a duty to develop a claimant’s medical record, and thus may be

required to consult medical advisors where that record appears to be incomplete.” Flener v.

Barnhart, 361 F.3d 442, 448 (7th Cir. 2004). “The duty is lower when a lawyer makes the

claimant’s case for him.” Bertaud v. O’Malley, 88 F.4th 1242, 1245 (7th Cir. 2023). But in any

case, “the reviewing court defers to the ALJ on the question of how much evidence must be

gathered. Deference comes from the practical reality that no record is “complete”—one may

always obtain another medical examination, seek the views of one more consultant, wait six

months to see whether the claimant’s condition changes, and so on.” Id. (quotation marks and

citations omitted).

In this case, the ALJ rejected a medical opinion not because she thought the record was

deficient, but because the author of the opinion was not readily identifiable. As explained in Ms.

Hayes’s opening brief, there is a reasonable likelihood that the opinion was produced by Dr.

Lazoff, as it appears to be the product of “Physical Medicine Consultants” based upon the

documents header. (See Def.’s Br., DE 7 at 13.) But regardless of who authored the opinion, the

ALJ could have easily contacted Ms. Hayes’s attorney before rejecting it due to uncertainty

about its source. The ALJ could have also contacted Physical Medicine Consultants. See 20

C.F.R. § 404.1520b(b) (stating that, among other things, the agency “may recontact [claimant’s]

medical source“ in an attempt “to resolve the inconsistency or insufficiency” in the record). The

Commissioner cites no authority, and the Court can find none either, for the proposition that an

ALJ can reject a medical opinion solely on the grounds that the signature is illegible even if other

identifying information is present. This is not the case in which the claimant failed to submit

evidence and is relying on the ALJ to do her work. The medical form was already in the record,

and there was no clear indication that the ALJ would not recognize its origin: the header of the

form was clearly identifiable, and the signature—although illegible—was present. While

confirming authorship might have caused delay in issuing the decision, the ALJ should not have

rejected a medical opinion over ambiguity that could have been reasonably clarified. See Michael

v. Astrue, 543 F. Supp. 2d 860, 866 (N.D. Ill. 2008) (finding reversible error where, among other

things, the ALJ gave no weight to an exhibit because the signature was illegible).

Likewise, the ALJ’s finding in the alternative that “the evidence as a whole failed to

document . . . significant functional limitations” does not sufficiently address the supportability

and consistency factors. Without more, the ALJ’s statement fails to provide a basis for a

meaningful review. According to the medical form, Ms. Hayes is significantly limited in

squatting, kneeling, pushing and pulling, and lifting. It also indicates that she should never stoop,

bend, balance, climb, or be exposed to unprotected heights. These limitations are not reflected in

the RFC. In rejecting the opinion, the ALJ did not elaborate on what “evidence as a whole”

contradicted the opinion, and her lack of explanation leaves the Court to guess which portions of

the evidence the ALJ specifically believed undermined the medical opinion about Ms. Hayes’s

capabilities.

In addition, to the extent that the ALJ did contrast the findings noted on the medical form

and the evidence at large, she appears to be comparing apples to oranges. The opinion in the

form addresses Ms. Hayes’s ability to lift, carry, push, pull, stoop, bend, squat, kneel, crawl,

balance, and climb. (R. at 1114.) Yet the ALJ contrasts these limitations with Ms. Hayes’s gait

and ability to walk independently. (R. at 31–32.) And although the ALJ references Ms. Hayes’s

“generally normal strength,” she does not specify which body part this refers to, nor does she

explain how this finding invalidates or contradicts described in the medical opinion.

The regulations require that ALJs explain how they considered the supportability and

consistency factors for a medical opinion. 20 C.F.R. § 404.1520c(b). Here, the ALJ simply

provided her conclusion––that the opinion conflicted with the evidence as a whole––without

giving any indication of which specific evidence she considered in reaching that determination.

As other judges in this district have recognized, such general statements unsupported by further

explanation are insufficient under the new regulations and require remand because they create no

logical bridge between the medical evidence and the ALJ’s conclusion. See Tammy M. v. Saul,

2021 WL 2451907, at *8 (N.D. Ind. June 16, 2021) (“As this Court has set forth, the ALJ

decision cannot stand under the new regulations when the ALJ finds the opinion not persuasive

because it is inconsistent with medical evidence but does not explain why that evidence is

inconsistent with the opinion.”); Michael v. Saul, 2021 WL 1811736, at *11 (N.D. Ind. May 6,

2021) (citing Moore v. Colvin, 743 F.3d 1118, 1121 (7th Cir. 2014)) (“[T]he ALJ cannot merely

summarize the evidence, as a whole, and then conclude that [the doctor’s] opinions are not

consistent with the evidence as a whole. Rather, the ALJ must build a logical analytical bridge

explaining what particular evidence undermined [the doctor’s] opinions and why.”) Without any

reasoning beyond the ALJ’s conclusion, the Court can only guess which evidence she relied on

and cannot determine whether she properly evaluated the medical opinions. The ALJ’s failure to

adequately address the supportability and consistency factors warrants remand. See Tammy M.,

2021 WL 2451907, at *7–8.

The Court recognizes the considerable burden that ALJs shoulder daily. Further, the

Court recognizes that their decisions are entitled to the benefit of harmless error analysis when

evaluating medical opinions. McKinsey v. Astrue, 641 F.3d 884, 891–92 (7th Cir. 2011) (finding

harmless error when the ALJ failed to assign weight to a state agency physician’s opinion);

Jason M. v. Kijakazi, 2022 WL 2071096, *5–*6 (S.D. Ind. June 9, 2022) (applying harmless

error analysis to an alleged failure to consider a medical opinion). An error is harmless if, upon

examination of the record, the reviewing Court can “predict with great confidence what the result

of the remand will be.” Wilder v. Kijakazi, 22 F.4th 644, 654 (7th Cir. 2022). Yet the Court

cannot reach such a conclusion here because PA Cua’s opinions, and the opinions expressed on

the medical form with the illegible signature, are central to the outcome of this case.

D. Conclusion

For these reasons, the Court REVERSES the Agency’s decision and REMANDS this

matter to the Agency for further proceedings consistent with this opinion. The Clerk is directed

to prepare a judgment for the Court’s approval.

SO ORDERED.

ENTERED: June 10, 2025

/s/ JON E. DEGUILIO

Judge

United States District Court