Brown Jr. v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedFebruary 3, 2025
Docket3:24-cv-05474
StatusUnknown

This text of Brown Jr. v. Commissioner of Social Security (Brown Jr. 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
Brown Jr. v. Commissioner of Social Security, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 CASEY E. B., JR., CASE NO. 3:24-CV-5474-DWC 11 Plaintiff, v. ORDER REVERSING AND 12 REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 13 SECURITY, 14 Defendant.

15 16 Plaintiff filed this action under 42 U.S.C. § 405(g) seeking judicial review of Defendant’s 17 denial of his application for supplemental security income benefits (“SSI”).1 After considering 18 the record, the Court concludes the Administrative Law Judge (“ALJ”) erred in his evaluation of 19 certain medical opinion evidence. Had the ALJ properly considered these opinions, Plaintiff’s 20 residual functional capacity (“RFC”) may have included additional limitations, or the ultimate 21 determination of disability may have changed. The ALJ’s error is, therefore, not harmless, and 22 23 1 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties have 24 consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 4. 1 this matter is reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the 2 Commissioner of Social Security (“Commissioner”) for further proceedings consistent with this 3 order. 4 I. Factual and Procedural History

5 Plaintiff filed a claim for SSI on March 1, 2019, alleging disability beginning on 6 November 27, 2018, due to traumatic brain injury, depression, memory issues, asthma, right 7 ankle pain, migraines, anxiety, anger, post-traumatic stress disorder (“PTSD”), and insomnia. 8 Dkt. 10, Administrative Record (“AR”) 328–49. His application was denied at the initial level 9 and on reconsideration. AR 142, 157. He requested a hearing before an ALJ, which took place on 10 October 22, 2020. AR 104–41, 212–15. Plaintiff was represented by counsel at the hearing. See 11 AR 104. On December 2, 2020, the ALJ issued an unfavorable decision denying benefits. AR 12 174–94. The Appeals Council granted Plaintiff’s request for review and remanded his claim for a 13 new hearing. AR 195–201, 265–68. 14 The new hearing took place on March 23, 2023. AR 70–103. On June 1, 2023, the ALJ

15 issued another unfavorable decision finding Plaintiff was not disabled. AR 28–51. The Appeals 16 Council denied Plaintiff’s request for review, making the ALJ’s decision the final decision of the 17 Commissioner. AR 1–7, 325–27. Plaintiff appealed to this Court. See Dkts. 1, 7. 18 II. Standard of Review 19 When reviewing the Commissioner’s final decision under 42 U.S.C. § 405(g), this Court 20 may set aside the denial of social security benefits if the ALJ’s findings are based on legal error 21 or are not supported by substantial evidence in the record. Bayliss v. Barnhart, 427 F.3d 1211, 22 1214 n.1 (9th Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). Substantial 23 evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a

24 1 conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (quoting Consol. Edison Co. v. NLRB, 2 305 U.S. 197, 229 (1938)). “We review only the reasons provided by the ALJ in the disability 3 determination and may not affirm the ALJ on a ground upon which he did not rely.” Garrison v. 4 Colvin, 759 F.3d 995, 1010 (9th Cir. 2014).

5 “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue, 6 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a). 7 Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to 8 the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 9 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. 10 III. Discussion 11 Plaintiff argues the ALJ erred in his consideration of certain medical opinion evidence, 12 Plaintiff’s testimony about the severity of his symptoms, and lay witness testimony, leading to an 13 erroneous RFC and step five findings. Dkt. 15 at 2. He contends the proper remedy for these 14 errors is remand for an award of benefits. Id.

15 The ALJ found Plaintiff had the severe impairments of post-concussive syndrome, PTSD, 16 bipolar disorder, and social anxiety disorder. AR 34. Despite these impairments, the ALJ found 17 Plaintiff had the RFC to perform a full range of work at all exertional levels with certain 18 nonexertional limitations: 19 The claimant can only understand, remember, and apply short, simple instructions. The claimant is limited to performing routine, predictable tasks. The claimant is 20 limited to work that is not performed in a fast-paced production rate environment. The claimant is limited to making simple decisions. The claimant can have 21 exposure to no more than occasional, routine work-place changes. The claimant can have no interaction with the general public and occasional interaction with co- 22 workers and supervisors.

23 AR 37. 24 1 A. Medical Opinion Evidence 2 Plaintiff contends the ALJ erred in evaluating certain medical evidence, including 3 opinion evidence from Kimberly Wheeler, Ph.D., and Alysa A. Ruddell, Ph.D. Dkt. 15 at 3–6. 4 When evaluating medical opinion evidence, ALJs “will not defer or give any specific evidentiary

5 weight, including controlling weight, to any medical opinion(s) or prior administrative medical 6 finding(s). . . .” 20 C.F.R. §§ 404.1520c(a), 416.920c(a).2 Instead, ALJs must consider every 7 medical opinion or prior administrative medical finding in the record and evaluate the 8 persuasiveness of each one using specific factors. Id. §§ 404.1520c(a), 416.920c(a). 9 The two most important factors affecting an ALJ’s determination of persuasiveness are 10 the “supportability” and “consistency” of each opinion. Id. §§ 404.1520c(a), 416.920c(a). 11 “Supportability means the extent to which a medical source supports the medical opinion by 12 explaining the ‘relevant . . . objective medical evidence.’” Woods v. Kijakazi, 32 F.4th 785, 791– 13 92 (9th Cir. 2022) (quoting 20 C.F.R. § 404.1520c(c)(1)); see also 20 C.F.R. § 416.920c(c)(1). 14 An opinion is more “supportable,” and thus more persuasive, when the source provides more

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