Summary
This Report and Recommendation addresses Sylvia Denise James’s challenge to the Commissioner of Social Security’s denial of Disability Insurance Benefits. The magistrate judge recommends vacating the Commissioner’s decision and remanding under sentence four of 42 U.S.C. § 405(g), finding that the ALJ inadequately evaluated Plaintiff’s mental impairments at Steps Two and Four and failed to provide an accurate and logical bridge between the evidence and the conclusions.
Holdings
- The magistrate judge recommended finding that the ALJ's Step Two analysis was not supported by substantial evidence because the ALJ relied on work activity without addressing evidence that mental-health symptoms led to termination from that job and similar work, and mischaracterized the record as showing that James declined mental-health referrals.
- The magistrate judge recommended finding that the ALJ inadequately explained whether and how James's mental impairments were considered in the RFC, requiring vacatur and remand for further proceedings.
Questions Presented
- Whether the ALJ's Step Two finding that James's mental impairments were non-severe was supported by substantial evidence.
- Whether the ALJ adequately considered James's mental impairments in formulating the residual functional capacity at Step Four.
- Whether the ALJ's explanation accurately characterized the record and built an accurate and logical bridge between the evidence and the conclusions.
Disposition
other
Cases Cited (32)
- Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987)(followed)
- Walters v. Commissioner of Social Security, 127 F.3d 525, 529 (6th Cir. 1997)(followed)
- Blakley v. Commissioner of Social Security, 581 F.3d 399, 405-06 (6th Cir. 2009)(followed)
- Heston v. Commissioner of Social Security, 245 F.3d 528, 535 (6th Cir. 2001)(followed)
- Besaw v. Secretary of Health & Human Services, 966 F.2d 1028, 1030 (6th Cir. 1992)(followed)
- Brainard v. Secretary of Health & Human Services, 889 F.2d 679, 681 (6th Cir. 1989)(followed)
- McClanahan v. Commissioner of Social Security, 474 F.3d 830, 833 (6th Cir. 2006)(followed)
- Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986)(followed)
- Garner v. Heckler, 745 F.2d 383, 387 (6th Cir. 1984)(followed)
- Rabbers v. Commissioner of Social Security Administration, 582 F.3d 647, 651 (6th Cir. 2009)(followed)
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