Maldonado v. Commissioner of Social Security Administration, 1:24-cv-00415

Aaron Maldonado applied for Child Insurance Benefits (CIB) and Supplemental Security Income (SSI) based on alleged disability due to mental and physical impairments, including Asperger syndrome, epilepsy, and depression.
Relevant benefit periods were (1) for CIB: September 2008–September 2012 (ages 18–22); (2) for SSI, generally from November 2021 onward.
Maldonado had limited work history, received special education, lived with his parents, and experienced anxiety, depressive symptoms, and stuttering.
Multiple psychological and consultative reports found varying degrees of mental impairment but generally indicated at most moderate limitations in functioning.
The Administrative Law Judge (ALJ) found Maldonado had severe impairments but concluded he was not disabled under the Social Security Act during either relevant period, and that jobs existed he could perform.
Maldonado appealed the final decision, arguing errors in evaluation of his mental impairments and assessment of medical opinion evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the ALJ err in evaluating the severity of mental impairments (Step 3)?	ALJ minimized or failed to fully consider evidence; should have found marked (not moderate) limitations.	ALJ reasonably found moderate limitations, supported by substantial evidence and a detailed discussion.	ALJ’s findings supported by substantial evidence; no error.
Did the ALJ adequately assess the persuasiveness of Dr. Krabbe’s opinion?	ALJ did not properly address supportability/consistency of Dr. Krabbe’s opinion on work pressure limits.	ALJ’s assessment addressed both supportability & consistency; opinion was vague & properly discounted.	ALJ’s evaluation was adequate; her findings on RFC were supported by substantial evidence.
Was it error not to discuss post-period psychiatric evidence (Dr. Ruedrich)?	Failure to discuss 2013 exam (shortly after CIB period) was error as it illuminated prior disability.	Later evidence had limited probative value, either duplicative or not clearly linked to the prior period.	No harmful error; ALJ’s omission did not deprive findings of substantial evidence.
Did the ALJ fail to separately analyze CIB and SSI periods?	Lack of separate analyses for CIB and SSI periods precluded meaningful court review.	ALJ’s decision clearly addressed both periods; no requirement for separate sectioning.	No error; ALJ’s discussion supported review for both timeframes.

Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (Review limited to whether ALJ applied correct law and findings supported by substantial evidence)
Bowen v. Yuckert, 482 U.S. 137 (1987) (Describes five-step disability adjudication sequence)
Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (Claimant bears burden at Steps 1–4; shifts to Commissioner at Step 5)
Jones v. Comm’r of Soc. Sec., 336 F.3d 469 (6th Cir. 2003) (Reviewing court cannot overturn if substantial evidence exists for ALJ’s conclusions)
Garner v. Heckler, 745 F.2d 383 (6th Cir. 1984) (Court may not try case de novo or resolve credibility/questions of fact)
Rabbers v. Comm’r Soc. Sec. Admin., 582 F.3d 647 (6th Cir. 2009) (Commissioner’s failure to follow own regs is error if it prejudices claimant)