Bechtold v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedOctober 18, 2023
Docket3:22-cv-05912
StatusUnknown

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

Bluebook
Bechtold v. Commissioner of Social Security, (W.D. Wash. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 JULIE B., Case No. 3:22-CV-05912 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S ACTING COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, 10 Defendant. 11 12 BACKGROUND 13 Plaintiff filed this action pursuant to 42 U.S.C. § 405(g) for judicial review of 14 defendant’s denial of plaintiff’s application for supplemental security income (“SSI”) and 15 disability insurance benefits (“DIB”). Pursuant to 28 U.S.C. § 636(c), Federal Rule of 16 Civil Procedure 73, and Local Rule MJR 13, the parties have consented to have this 17 matter heard by the undersigned Magistrate Judge. Dkt. 2. Plaintiff challenges the ALJ’s 18 decision finding that plaintiff was not disabled. Dkt. 4, Complaint. 19 Plaintiff filed her applications for SSI and DIB benefits on July 10, 2019. AR 21. 20 She alleged the date of onset was April 3, 2018. Id. The applications were denied, and 21 plaintiff appealed; the ALJ held a hearing on August 4, 2021, by phone. AR 38-71. 22 Plaintiff was not represented by counsel during the ALJ hearing but was assisted by a 23 non-attorney representative. AR 388-398. The ALJ published a decision on August 31, 24 2021, finding that plaintiff was not disabled. AR 21-32. 1 The ALJ determined that plaintiff had the following severe impairments: “morbid 2 obesity; left shoulder adhesive capsulitis; generalized anxiety disorder; post-traumatic 3 stress disorder (PTSD); and persistent depressive disorder.” AR 24. At step four, the 4 ALJ found plaintiff had the following residual functional capacity (RFC): “she could

5 perform light work, with the following limitations – “frequently climb ramps and stairs, but 6 never climb ropes, ladders, or scaffolds; occasionally balance, stoop, crouch, and kneel, 7 but never crawl; occasionally reach overhead with the left upper extremity; frequently 8 reach laterally and in front with the left upper extremity; frequently handle with the left 9 upper extremity; no exposure to vibrations, extreme cold, or workplace hazards, such as 10 moving machinery and unprotected heights; she can do simple, routine, repetitive tasks 11 with a reasoning level of 1-2, occasional superficial contact with the public, and 12 occasional contact with coworkers with no teamwork or collaborative tasks.” AR 26. 13 The ALJ found that plaintiff would not be able to perform her past work as a 14 Customer Service Representative. AR 30. But the ALJ found (at step five) plaintiff would

15 be able to perform occupations such as Routing Clerk, Marker, and Small Products 16 Assembler. AR 31. 17 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner's 18 denial of Social Security benefits if the ALJ's findings are based on legal error or not 19 supported by substantial evidence in the record as a whole. Revels v. Berryhill, 874 20 F.3d 648, 654 (9th Cir. 2017) (internal citations omitted). Substantial evidence is “‘such 21 relevant evidence as a reasonable mind might accept as adequate to support a 22 conclusion.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations 23 omitted). The Court must consider the administrative record as a whole. Garrison v.

24 1 Colvin, 759 F.3d 995, 1009 (9th Cir. 2014). The Court also must weigh both the 2 evidence that supports and evidence that does not support the ALJ’s conclusion. Id. 3 The Court may not affirm the decision of the ALJ for a reason upon which the ALJ did 4 not rely. Id. Rather, only the reasons identified by the ALJ are considered in the scope

5 of the Court’s review. Id. 6 DISCUSSION 7 A. Medical evidence. 8 Plaintiff argues the ALJ erred by failing to clarify the record in light of ambiguous 9 medical evidence submitted by Dr. Christmas Covell and Dr. Rafael Oliveras. Dkt. 11, 10 Plaintiff’s Opening Brief, at 2-3. Plaintiff also argues the ALJ erred in evaluating the 11 opinions of Dr. Jack Litman, Dr. David Morgan, and Dr. Howard Platter. Dkt. 11, at 3-8. 12 Plaintiff also contends the ALJ’s decision should be overturned because Dr. Bruce 13 Tapper’s opinion, which was provided to the Appeals Council after the ALJ published 14 their decision, requires a new hearing. Dkt. 11, at 18-19.

15 Under the 2017 regulations, the Commissioner “will not defer or give any specific 16 evidentiary weight . . . to any medical opinion(s) . . . including those from [the claimant’s] 17 medical sources.” 20 C.F.R. §§ 404.1520c(a), 416.920c(a). The ALJ must nonetheless 18 explain with specificity how he or she considered the factors of supportability and 19 consistency in evaluating the medical opinions. 20 C.F.R. §§ 404.1520c(a)–(b), 20 416.920c(a)–(b). 21 The Ninth Circuit considered the 2017 regulations in Woods v. Kijakazi, 32 F.4th 22 785 (9th Cir. 2022). The Court found that “the requirement that ALJ’s provide ‘specific 23

24 1 and legitimate reasons’1 for rejecting a treating or examining doctor’s opinion…is 2 incompatible with the revised regulations” because requiring ALJ’s to give a “more 3 robust explanation when discrediting evidence from certain sources necessarily favors 4 the evidence from those sources.” Id. at 792. Under the new regulations,

5 an ALJ cannot reject an examining or treating doctor's opinion as unsupported or inconsistent without providing an explanation supported by 6 substantial evidence. The agency must “articulate ... how persuasive” it finds “all of the medical opinions” from each doctor or other source, 20 7 C.F.R. § 404.1520c(b), and “explain how [it] considered the supportability and consistency factors” in reaching these findings, id. § 404.1520c(b)(2). 8 Id. 9 1. Mental Health Evidence 10 • Dr. Litman 11 The ALJ found that Dr. Litman’s assessment was unpersuasive because Dr. 12 Litman opined that plaintiff would be unable to work – an issue the ALJ found was only 13 for the Commissioner to decide, and thus the ALJ determined she could not consider 14 Dr. Litman’s entire assessment for any persuasive value. AR 30. 15 Dr. Litman found that plaintiff’s symptoms would interfere with her ability to 16 complete a regular workday. AR 592. During the examination (November 2019), Dr. 17 Litman reviewed plaintiff’s medical records and performed a mental status examination. 18 AR 586-593. He found that plaintiff would be a disruption to others around her and she 19 would not be able to complete a regular workday. AR 592. Dr. Litman observed that 20 plaintiff was experiencing recurring anxiety, depression, and PTSD, as a result of having 21 been subjected to sexual abuse by her father from the time she was about three years 22 23 1 See Murray v. Heckler, 722 F.2d 499, 501 (9th Cir. 1983) (describing the standard of “specific and legitimate 24 reasons”).

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Bechtold v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bechtold-v-commissioner-of-social-security-wawd-2023.