Christopher Cottingham v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviews Christopher Cottingham’s challenge to the denial of disability insurance benefits and supplemental security income. The court concludes that the Administrative Law Judge failed to adequately articulate whether Cottingham’s headaches medically equaled Listing 11.02 and vacates the Commissioner’s decision, remanding for further proceedings.

Holdings

1. The ALJ erred by failing to adequately address whether Cottingham's migraine headaches medically equaled Listing 11.02. The conclusory statement that no acceptable medical source had opined that the headaches were medically equivalent did not adequately address the criteria of Listings 11.02B and 11.02D or the factors identified in SSR 19-4p.
2. The error was not harmless.
3. Remand for further proceedings was the appropriate remedy rather than an award of benefits.

Questions Presented

1. Whether the ALJ adequately evaluated at step three whether Cottingham's primary headache disorder medically equaled Listing 11.02 under SSR 19-4p.
2. Whether the ALJ's error was harmless.
3. Whether the court should award benefits or remand for further administrative proceedings.

Disposition

reversed_and_remanded