Stephanie L. v. Commissioner of Social Security

CourtDistrict Court, E.D. Michigan
DecidedFebruary 26, 2026
Docket2:25-cv-10350
StatusUnknown

This text of Stephanie L. v. Commissioner of Social Security (Stephanie L. v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stephanie L. v. Commissioner of Social Security, (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

STEPHANIE L., Case No. 25-cv-10350 Plaintiff, Magistrate Judge Elizabeth A. Stafford v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER ON CROSS MOTIONS FOR SUMMARY JUDGMENT (ECF NOS. 10, 12)

I. Introduction Plaintiff Stephanie L. appeals the final decision of defendant Commissioner of Social Security (Commissioner), which denied her application for disability insurance benefits (DIB) and supplemental security income (SSI) under the Social Security Act. Both parties consented to the undersigned conducting all proceedings under 28 U.S.C. § 636(c) and moved for summary judgment. ECF No. 8; ECF No. 10; ECF No. 12. After a hearing below, an administrative law judge (ALJ) found: 1. Plaintiff had the severe impairments of “osteoarthritis, status post right total knee arthroplasty; right peroneal nerve neuropathy; and fibromyalgia.” ECF No. 6-1, PageID.167.

2. Plaintiff had no impairments that met or medically equaled a listed impairment. Id., PageID.169.

3. Plaintiff had the residual function capacity (RFC) to perform light work “except stand and/or walk 4 of 8 hours with the option to alternate between sitting and standing at approximate hourly intervals; never climb ladders; occasionally climb ramps and stairs, balance, stoop, kneel, crouch, and crawl; must avoid concentrated exposure to extreme cold and wetness; no work at unprotected heights, with unguarded moving mechanical parts, or on uneven or slippery terrain. Id.

Relying on the testimony from a vocational expert, the ALJ found that jobs existed in the national economy that plaintiff could perform, and that plaintiff was not disabled. Id., PageID.173-174. II. Analysis A. Under § 405(g), this Court’s review is limited to determining whether the Commissioner’s decision is supported by substantial evidence1 and conformed with proper legal standards. Gentry v. Comm’r of Soc. Sec., 741 F.3d 708, 722 (6th Cir. 2014).

1 Only the evidence in the record below may be considered when determining whether the ALJ’s decision is supported by substantial evidence. Bass v. McMahon, 499 F.3d 506, 513 (6th Cir. 2007). Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficient evidence to support the agency’s factual determinations. And whatever the meaning of substantial in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is more than a mere scintilla. It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Biestek v. Berryhill, 587 U.S. 97, 102-03 (2019) (cleaned up). The substantial-evidence standard does not permit the Court to independently weigh the evidence. Hatmaker v. Comm’r of Soc. Sec., 965 F. Supp. 2d 917, 930 (E.D. Tenn. 2013) (“The Court may not reweigh the evidence and substitute its own judgment for that of the Commissioner merely because substantial evidence exists in the record to support a different conclusion.”); see also Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284, 286 (6th Cir. 1994) (“If the Secretary’s decision is supported by substantial evidence, it must be affirmed even if the reviewing court would decide the matter differently, and even if substantial evidence also supports the opposite conclusion.”).

Plaintiff argues that the ALJ erred by finding her mental impairments to be non-severe and by failing to discuss those impairments in determining her residual functional capacity (RFC). ECF No. 10, PageID.1325-1336; ECF No. 13, PageID.1363-1368. The Court disagrees and affirms the ALJ’s decision.

B. The ALJ found plaintiff’s depression and anxiety to be non-severe impairments because they did “not cause more than minimal limitation in

the claimant’s ability to perform basic mental work activities” and were “well controlled on medication, with no side effects.” ECF No. 6-1, PageID.167- 171. Applying the paragraph B criteria, she found that plaintiff had mild limitations in two criteria and no limitations in two of them. Id., PageID.167-

169. And while the ALJ noted “the limitations identified in the ‘paragraph B’ criteria are not a residual functional capacity assessment,” she recognized her obligation to address plaintiff’s “mental residual functional capacity

assessment” at steps 4 and 5 of her decision. Id., PageID.168. After considering “all symptoms” and “the entire record,” the ALJ included no limitations in the RFC for plaintiff’s mental impairments. Id., PageID.166, 169, 172 (citing 20 C.F.R. § 404.1520(e), 404.1545, 416.945; Social

Security Ruling (SSR) 96-8p). In support of her conclusion, the ALJ noted that two state agency psychological consultants persuasively concluded that plaintiff had no

severe mental impairments: These opinions, the assessment that the claimant’s mental impairment[s] are not severe, are persuasive. The opinions are supported by explanation and consistent with the record as a whole, which documents minimal mental health complaints from the claimant, no psychiatric treatment, counseling, or emergency room visits for psychiatric complaints. The claimant’s long-term treatment plan with medications appears to manage her symptoms.

Id., PageID.171. The ALJ’s analysis aligns with that approved by the Sixth Circuit. In Emard v. Comm’r of Soc. Sec., the ALJ stated that she had reviewed the entire record and all symptoms, although she did not expressly discuss the plaintiff’s non-severe impairments in assessing the RFC. 953 F.3d 844, 851 (6th Cir. 2020). The court found that “[t]he ALJ’s express reference to SSR 96-8p, along with her discussion of the functional limitations imposed by [the plaintiff's] nonsevere impairments at step two of her analysis,” satisfied the requirements of 20 C.F.R. § 416.945(e) and SSR 96-8p. Id. at 852; see also Napier v. Comm’r of Soc. Sec., 127 F.4th 1000, 1007 (6th Cir. 2025) (“Considering the substantial evidence supporting the ALJ's findings that Napier's limitations were no more than mild and the ALJ's repeated statements that it took all of Napier’s limitations into account, we

hold that the ALJ adequately accounted for Napier’s limitations in the residual functional capacity analysis.”). Arguing that she required greater limitations for her mental impairments, plaintiff cites records showing that she was diagnosed with

major depression and prescribed medication, and treatment notes describing anxiety, excessive worrying, restlessness, irritability, and difficultly concentrating. ECF No. 10, PageID.1326 (citing ECF No. 6-1,

PageID.75, 90-91, 690-691). But a diagnosis says nothing about its disabling effects. Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988).

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Related

Bruce Coldiron v. Commissioner of Social Security
391 F. App'x 435 (Sixth Circuit, 2010)
Jordan v. Commissioner of Social Security
548 F.3d 417 (Sixth Circuit, 2008)
Bass v. McMahon
499 F.3d 506 (Sixth Circuit, 2007)
Hibbard v. Astrue
537 F. Supp. 2d 867 (E.D. Kentucky, 2008)
Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Jeffery Emard v. Comm'r of Soc. Sec.
953 F.3d 844 (Sixth Circuit, 2020)
Hatmaker v. Commissioner of Social Security
965 F. Supp. 2d 917 (E.D. Tennessee, 2013)
Higgs v. Bowen
880 F.2d 860 (Sixth Circuit, 1988)
Edna Napier v. Comm'r of Soc. Sec.
127 F.4th 1000 (Sixth Circuit, 2025)

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Bluebook (online)
Stephanie L. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephanie-l-v-commissioner-of-social-security-mied-2026.