Eddington v. Commissioner of Social Security, 1:24-cv-00564

Amy Marie Eddington applied for Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI), alleging disability due to various physical and mental impairments beginning July 2020.
Her applications were denied at both initial and reconsideration levels; she sought review by an Administrative Law Judge (ALJ).
The ALJ found Eddington had no severe medically determinable impairments and denied benefits at Step Two of the disability evaluation process.
Eddington challenged the decision in federal court, arguing that the ALJ's finding lacked substantial evidence and that her symptoms and limitations exceeded the de minimis severity threshold.
The case was referred to a Magistrate Judge for a Report and Recommendation.
The Magistrate Judge recommended vacating and remanding the Commissioner’s decision due to errors in the ALJ's severity analysis and failure to properly address reasons for limited treatment, such as lack of insurance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ’s Step 2 Finding: No Severe Impairments	Eddington contends the evidence shows more than minimal limitations and Step Two threshold is low.	Commissioner argues state agency consultants found no severe impairment and activities did not show disabling limitations.	Step Two finding lacked substantial evidence; error not harmless; remand required.
Evaluation of Medical/Treatment Evidence	ALJ erred by not considering inability to afford care for lack of treatment, in violation of SSR 16-3p.	Treatment gaps reasonable since no diagnosis justified further care.	ALJ failed to consider inability to pay; this contravened required legal standards.
Consideration of Work Experience	ALJ wrongly considered Eddington's work after onset date as evidence against severity at Step Two.	Work after onset supported non-severity.	Work history irrelevant at Step Two; use was improper by ALJ.
Harmless Error	ALJ’s error at Step Two was not harmless since review ended there, precluding full evaluation.	Any error deemed harmless; sufficient support otherwise.	Error not harmless because the process did not proceed beyond Step Two.

Reynolds v. Comm’r of Soc. Sec., 424 F. App’x 411 (6th Cir. 2011) (discussing the narrow scope of judicial review of SSA decisions)
Ealy v. Comm’r of Soc. Sec., 594 F.3d 504 (6th Cir. 2010) (five-step sequential evaluation for disability claims)
Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (substantial evidence standard defined)
Buxton v. Halter, 246 F.3d 762 (6th Cir. 2001) (explains the "zone of choice" for findings supported by substantial evidence)
Higgs v. Bowen, 880 F.2d 860 (6th Cir. 1988) (Step Two presents only a de minimis hurdle in disability evaluation)
Brainard v. Sec’y of Health & Human Servs., 889 F.2d 679 (6th Cir. 1989) (court does not reweigh evidence or make credibility determinations)