Cotton v. Social Security Administration, Commissioner

Plaintiff Larry Cotton applied for disability insurance benefits and supplemental security income, alleging multiple physical and mental impairments that prevented him from working. After his claims were denied initially and on reconsideration, an administrative law judge held a hearing and concluded that Cotton could perform his past relevant work, thus denying him benefits. Cotton filed suit in the United States District Court for the Eastern District of Michigan, arguing that the ALJ improperly evaluated the medical opinion evidence from his treating physician and failed to properly assess his subjective complaints. On September 28, 2018, the district court reviewed the administrative record and found that the ALJ's decision lacked the support of substantial evidence, particularly in the weighing of medical opinions. The court reversed the Commissioner's final decision and remanded the case for further administrative proceedings.

The district court reversed the Commissioner of Social Security's decision and remanded the case for further proceedings, finding the ALJ's decision was not supported by substantial evidence.

Whether the administrative law judge violated the treating physician rule and failed to properly articulate reasons for discounting the opinions of the claimant's treating sources, and whether the evaluation of the claimant's subjective symptom allegations was supported by substantial evidence.

The decision reinforced the requirement that administrative law judges must provide specific, well-articulated reasons when rejecting or giving less weight to the medical opinions of treating physicians. It highlighted the judiciary's role in ensuring that disability claimants receive a fair hearing and that administrative decisions are grounded in a proper application of the law and evidence.