Brown v. Commissioner of Social Security

District Court, W.D. Washington·Decided April 22, 2024·No. 3:23-cv-05391·Unknown

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 CASE NO. 3:23-CV-5391-DWC 11 Plaintiff, ORDER REVERSING AND 12 v. REMANDING DEFENDANT’S DECISION TO DENY BENEFITS 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 applications for supplemental security income benefits (“SSI”) and disability 18 insurance benefits (“DIB”).1 After considering the record, the Court concludes the 19 Administrative Law Judge (“ALJ”) erred in his evaluation of Plaintiff’s subjective symptom 20 testimony. Had the ALJ properly addressed Plaintiff’s testimony, he may have included 21 additional limitations in Plaintiff’s residual functional capacity (“RFC”) or reached a different 22

23 1 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties 24 have consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 2. 1 conclusion regarding disability. The ALJ’s error is, therefore, not harmless, and this matter is 2 reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the Commissioner of 3 Social Security (“Commissioner”) for further proceedings consistent with this Order. 4 I. Factual and Procedural History

5 Plaintiff filed claims for DIB and SSI in July 2020, alleging disability beginning August 6 28, 2014. Dkt. 10, Administrative Record (“AR”) 254, 260. His applications were denied at the 7 initial level and on reconsideration. AR 65–66, 125–26. He requested a hearing before an ALJ, 8 which took place on January 25, 2022. AR 35–64, 150. Plaintiff was represented by counsel at 9 the hearing. See AR 35. 10 The ALJ issued an unfavorable decision denying benefits on February 11, 2022. AR 13– 11 34. In his written decision, the ALJ found Plaintiff had the severe impairments of degenerative 12 disc disease of the lumbar spine and right knee osteoarthritis. AR 19. He determined Plaintiff had 13 the RFC to perform sedentary work with certain additional limitations: 14 [H]e is further limited to no more than occasional balancing, stooping, crouching, crawling, kneeling, or climbing of ramps and stairs. The claimant would be 15 precluded from climbing ropes, ladders, or scaffolds, and would need to avoid concentrated exposure to unprotected heights, moving machinery, and similar 16 hazards. The claimant should avoid walking on grass and on uneven surfaces.

17 AR 20. The ALJ found Plaintiff was unable to perform his heavy past relevant work as a pipe 18 fitter. AR 26–27. However, based on the testimony of the vocational expert, the ALJ determined 19 there were other jobs existing in significant numbers in the national economy that Plaintiff could 20 perform. AR 27–28. 21 The Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the 22 final decision of the Commissioner. AR 1–6. Plaintiff appealed to this Court. See Dkts. 1, 4. 23 24 1 II. Standard of Review 2 When reviewing the Commissioner’s final decision under 42 U.S.C. § 405(g), this Court 3 may set aside the denial of social security benefits if the ALJ’s findings are based on legal error 4 or are not supported by substantial evidence in the record. Bayliss v. Barnhart, 427 F.3d 1211,

5 1214 n.1 (9th Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). Substantial 6 evidence “is a highly deferential standard of review[.]” Valentine v. Comm’r of Soc. Sec. Admin., 7 574 F.3d 685, 690 (9th Cir. 2009). Evidence is “substantial” when it is “more than a mere 8 scintilla.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). “It means—and means only—such 9 relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. 10 (cleaned up). 11 “[T]he ALJ ‘is responsible for determining credibility, resolving conflicts in medical 12 testimony, and for resolving ambiguities.’” Ford v. Saul, 950 F.3d 1141, 1149 (9th Cir. 2020) 13 (quoting Andrews v. Shalala, 53 F.3d 1035, 1039 (9th Cir. 1995)). Accordingly, “[e]ven if the 14 evidence is ‘susceptible to more than one rational interpretation, it is the ALJ's conclusion that

15 must be upheld.’” Farlow v. Kijakazi, 53 F.4th 485, 488 (9th Cir. 2022) (quoting Burch v. 16 Barnhart, 400 F.3d 676, 679 (9th Cir. 2005)). However, ALJs must “set forth the reasoning 17 behind [their] decisions in a way that allows for meaningful review.” Brown-Hunter v. Colvin, 18 806 F.3d 487, 492 (9th Cir. 2015). “A clear statement of the agency’s reasoning is necessary 19 because [the Court] can affirm the agency’s decision to deny benefits only on the grounds 20 invoked by the agency.” Id. 21 “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue, 22 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a). 23 Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to

24 1 the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 2 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. 3 III. Discussion 4 Plaintiff contends the ALJ erred in discounting his subjective symptom testimony,

5 evaluating the medical evidence, and formulating his RFC. Dkt. 15 at 1. 6 A. Subjective Symptom Testimony 7 Plaintiff argues the ALJ supplied insufficient reasons for rejecting Plaintiff’s testimony 8 about the severity of his symptoms. Id. at 7. 9 1. Subjective Symptom Testimony Standard 10 “An ALJ engages in a two-step analysis to determine whether a claimant's testimony 11 regarding subjective pain or symptoms is credible.” Garrison v. Colvin, 759 F.3d 995, 1014 (9th 12 Cir. 2014). At the first step, the ALJ determines whether the claimant has presented objective 13 medical evidence of an underlying impairment that could reasonably be expected to produce the 14 pain or other symptoms alleged. Id. This evidence need not validate the severity of the alleged

15 symptoms; rather, “the medical evidence need only establish that the impairment could 16 reasonably be expected to cause some degree of the alleged symptoms.” Smith v. Kijakazi, 14 17 F.4th 1108, 1111 (9th Cir. 2021).

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