Lynn Ulman v. Commissioner of Social Security, 693 F.3d 709

Ulman applied for disability benefits, with insured status expired before alleged onset; disability must begin on/before expiration and continue to filing.
ALJ found claimant had severe impairments but could perform sedentary work with sit/stand option and other modest limits, denying benefits.
Claimant testified to constant, high pain and inability to concentrate, supported by treating physician Dr. Mankoff’s restrictions.
ALJ's credibility finding relied in part on a misdated ladder incident (2006 vs 2001), prompting a claim of factual error.
District court and magistrate judge affirmed denial, applying harmless error reasoning for the credibility issue.
On appeal, court reviews for substantial evidence and proper legal standards, addressing whether the misreading of record was harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the ALJ’s credibility error harmless?	Ulman argues the error taints credibility finding.	Ulman contends substantial evidence remains supporting credibility despite error.	Harmless error; substantial evidence supports credibility.

Valley v. Comm'r of Soc. Sec., 427 F.3d 388 (6th Cir. 2005) (standard of review for substantial evidence in SSA cases)
Crum v. Sullivan, 921 F.2d 642 (6th Cir. 1990) (de novo review limited; credibility not redetermined)
Rogers v. Comm'r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (substantial evidence standard; proper legal standards required)
Bass v. McMahon, 499 F.3d 506 (6th Cir. 2007) (harmless error principle in SSA credibility)
Carmickle v. Comm'r of Soc. Sec., 533 F.3d 1155 (9th Cir. 2008) (harmless error when remaining evidence supports credibility)
Wilson v. Comm'r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (embraces harmless error concept in weight given to treating physicians)
S.E.C. v. Chenery Corp., 318 U.S. 80 (Supreme Court 1943) (agency action must be based on record rather than post hoc justification)