Castaneda v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedMarch 29, 2022
Docket3:20-cv-08093
StatusUnknown

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

Bluebook
Castaneda v. Commissioner of Social Security Administration, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Victoria Castaneda, No. CV-20-08093-PCT-SMB

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 At issue is the denial of Plaintiff Victoria Castaneda’s Application for Social 16 Security Disability Insurance (“SSDI”) benefits by the Social Security Administration 17 (“SSA”) under the Social Security Act (the “Act”). Plaintiff filed a Complaint, (Doc. 1), 18 and an Opening Brief, (Doc. 14), seeking judicial review of that denial. Defendant SSA 19 filed an Answering Brief, (Doc. 15), to which Plaintiff replied, (Doc. 16). The Court has 20 reviewed the parties’ briefs, the Administrative Record, (Doc. 11), and the Administrative 21 Law Judge’s (“ALJ’s”) decision, (Doc. 11 at 25–29), and will vacate the ALJ’s decision 22 and remand for the reasons addressed herein. 23 I. BACKGROUND 24 Plaintiff filed an Application for SSDI benefits in June 2016, alleging a disability 25 beginning on May 10, 2016. (Doc. 11-3 at 19.) Plaintiff’s claim was initially denied, and 26 a hearing was held before ALJ Mucerino on November 29, 2018. Plaintiff’s Application 27 was denied by the ALJ on March 25, 2019. (Id. at 19-32). Thereafter, the Appeals Council 28 denied Plaintiff’s Request for Review of the ALJ’s decision on February 20, 2020, and this 1 appeal followed. 2 Plaintiff alleges disability due to, in relevant part, neck and knee pain, arthritis, and 3 tendonitis. After considering the medical evidence and opinions, the ALJ determined that 4 Plaintiff “has not been under a disability within the meaning of the Social Security Act 5 from May 10, 2016, through the date of this decision.” (Id. at 20.) The ALJ found claimant 6 to have several severe impairments including, in part, morbid obesity, asthma, degenerative 7 disc disease of the cervical spine, degenerative joint disease of the left knee, and 8 osteoarthritis in both knees and the lumbar spine. (Id. at 4.) The ALJ concluded, 9 nevertheless, that claimant had the residual functional capacity (“RFC”) to perform 10 sedentary work and that she is capable of performing past relevant work as a receptionist. 11 (Id. at 6–13.) 12 Plaintiff argues that the ALJ erred by rejecting treating source opinions and 13 improperly rejecting Plaintiff’s symptom testimony. The Commissioner argues that the 14 ALJ’s opinion is free of harmful error. The Court has reviewed the medical record and 15 will discuss the pertinent evidence in addressing the issues raised by the parties. 16 II. LEGAL STANDARDS 17 An ALJ’s factual findings “shall be conclusive if supported by substantial 18 evidence.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). The Court may set aside 19 the Commissioner’s disability determination only if it is not supported by substantial 20 evidence or is based on legal error. Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007). 21 Substantial evidence is relevant evidence that a reasonable person might accept as adequate 22 to support a conclusion considering the record as a whole. Id. Generally, “[w]here the 23 evidence is susceptible to more than one rational interpretation, one of which supports the 24 ALJ’s decision, the ALJ’s conclusion must be upheld.” Thomas v. Barnhart, 278 F.3d 947, 25 954 (9th Cir. 2002). In determining whether to reverse an ALJ’s decision, the district court 26 reviews only those issues raised by the party challenging the decision. See Lewis v. Apfel, 27 236 F.3d 503, 517 n.13 (9th Cir. 2001). 28 III. DISCUSSION 1 Plaintiff argues that the ALJ committed harmful error in evaluating Plaintiff’s 2 symptom testimony and in weighing the medical opinion. The Commissioner argues that 3 the ALJ’s opinion did not reject Plaintiff’s subjective complaints, but rather, used them to 4 evaluate her functional limitations. Additionally, the Commissioner argues that the ALJ 5 properly weighed the medical opinions. The Court has reviewed the medical and 6 administrative records and agrees with the Plaintiff that the ALJ improperly weighed the 7 medical opinions. 8 A. Plaintiff’s Symptom Testimony 9 An ALJ performs a two-step analysis to evaluate a claimant’s testimony regarding 10 pain and symptoms. Garrison v. Colvin, 759 F.3d 995, 1014 (9th Cir. 2014). First, the 11 ALJ evaluates whether the claimant has presented objective medical evidence of an 12 impairment that “could reasonably be expected to produce the pain or symptoms alleged.” 13 Lingenfelter v. Astrue, 504 F.3d 1028, 1035–36 (9th Cir. 2007) (quoting Bunnell v. 14 Sullivan, 947 F.2d 341, 344 (9th Cir. 1991)) (internal quotation marks omitted). Second, 15 absent evidence of malingering, an ALJ may only discount a claimant’s allegations for 16 reasons that are “specific, clear and convincing” and supported by substantial evidence. 17 Molina v. Astrue, 674 F.3d 1104, 1112 (9th Cir. 2012). 18 “[T]he ALJ must specifically identify the testimony she or he finds not to be credible 19 and must explain what evidence undermines the testimony.” Holohan v. Massanari, 246 20 F.3d 1195, 1208 (9th Cir. 2001). General findings are insufficient. Id. “Although the 21 ALJ’s analysis need not be extensive, the ALJ must provide some reasoning in order for 22 [the Court] to meaningfully determine whether the ALJ’s conclusions were supported by 23 substantial evidence.” Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1099 (9th 24 Cir. 2014). “[T]he ALJ may consider inconsistencies either in the claimant’s testimony or 25 between the testimony and the claimant’s conduct.” Molina, 674 F.3d at 1112. For 26 instance, the ALJ may consider “whether the claimant engages in daily activities 27 inconsistent with the alleged symptoms.” Id. (quoting Lingenfelter, 504 F.3d at 1040). 28 Plaintiff argues the ALJ required proof of the severity of the symptoms and did not 1 tie in the medical records with any particular symptom testimony. (Doc. 14 at 11.) The 2 Commissioner argues the ALJ did identify specific examples of evidence that did not 3 support Plaintiff’s symptom testimony and properly used the testimony to evaluate 4 Plaintiff’s RFC. (Doc. 15.) 5 Here, the ALJ did not reject Plaintiff’s testimony of neck pain, muscle spasms, and 6 knee pain but considered the limitations caused by those symptoms when evaluating her 7 RFC. (Doc. 11-3 at 26). As for Plaintiff’s claim of disabling pain, the ALJ specifically 8 pointed to many places in the record showing pain relief given by conservative treatments. 9 (Id. at 26). Plaintiff also argues the ALJ improperly rejected her testimony regarding side 10 effects from medication. However, the ALJ provided specific citations to multiple places 11 in the record where Plaintiff denied such side effects. The ALJ also considered evidence 12 of Plaintiff’s ability to participate in activities of daily living when evaluating the 13 credibility of her symptom testimony. 14 Therefore, the Court finds no error in the ALJ’s evaluation of Plaintiff’s symptom 15 testimony. 16 B. Evaluation of Medical Testimony 17 While “[t]he ALJ must consider all medical opinion evidence,” there is a hierarchy 18 among the sources of medical opinions. Tommasetti v.

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Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
Tommasetti v. Astrue
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Orn v. Astrue
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Lingenfelter v. Astrue
504 F.3d 1028 (Ninth Circuit, 2007)
Karen Garrison v. Carolyn W. Colvin
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Kanika Revels v. Nancy Berryhill
874 F.3d 648 (Ninth Circuit, 2017)
Biestek v. Berryhill
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Castaneda v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/castaneda-v-commissioner-of-social-security-administration-azd-2022.