Chase v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedApril 25, 2025
Docket2:24-cv-01880
StatusUnknown

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

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 MARK DAVID C., 9 Plaintiff, Case No. C24-1880-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of his application for Disability Insurance Benefits. 15 Plaintiff contends that the administrative law judge (“ALJ”) erred in assessing the medical 16 opinion evidence and his testimony. (Dkt. # 7.) The Commissioner filed a response arguing that 17 the ALJ’s decision is free of legal error, supported by substantial evidence, and should be 18 affirmed. (Dkt. # 9.) Plaintiff filed a reply. (Dkt. # 11.) Having considered the ALJ’s decision, 19 the administrative record (“AR”), and all memoranda of record, the Court AFFIRMS the 20 Commissioner’s final decision and DISMISSES the case with prejudice.1 21 22 23

1 The parties consented to proceed before the undersigned Magistrate Judge. (Dkt. # 2.) 1 II. BACKGROUND 2 Plaintiff was born in 1968, has a high school education, and has worked as a licensed 3 practical nurse and medical assistant. AR at 31. Plaintiff was last gainfully employed in July 4 2017. Id. at 24.

5 In February 2019, Plaintiff applied for benefits, alleging disability as of July 2017. AR at 6 22. Plaintiff’s applications were denied initially and on reconsideration, and Plaintiff requested a 7 hearing. Id. After the ALJ conducted a hearing in March 2024, the ALJ issued a decision finding 8 Plaintiff not disabled. Id. 9 Using the five-step disability evaluation process,2 the ALJ found, in pertinent part, 10 Plaintiff did not engage in substantial gainful from July 2017 to his date last insured in December 11 2022. AR at 24. Plaintiff had the severe impairments of degenerative changes of the spine, 12 posttraumatic stress disorder (“PTSD”), major depressive disorder, osteoarthritis of both ankles, 13 and obesity. Id. The ALJ found that Plaintiff had the residual functional capacity (“RFC”) to 14 perform light work with some physical, mental, and social limitations. Id. at 26. Based on

15 Plaintiff’s mental health symptoms he was limited to a low level of work pressure, with only 16 occasional interaction with coworkers, supervisors, and the public. Id. 17 As the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision is the 18 Commissioner’s final decision. AR at 13. Plaintiff appealed the final decision of the 19 Commissioner to this Court. (Dkt. # 1.) 20 III. LEGAL STANDARDS 21 Under 42 U.S.C. § 405(g), this Court may overturn the Commissioner’s denial of social 22 security benefits if the ALJ’s decision rests on legal error or is not supported by substantial 23

2 20 C.F.R. § 404.1520. 1 evidence. Smartt v. Kijakazi, 53 F.4th 489, 494 (9th Cir. 2022). Substantial evidence is defined 2 as “such relevant evidence as a reasonable mind might accept as adequate to support a 3 conclusion.” Biestek v. Berryhill, 587 U.S. 97, 102–03 (2019) (cleaned up). In applying this 4 standard, the Court must consider the record as a whole to determine whether it contains

5 sufficient evidence to support the ALJ’s findings. Id. 6 Although the Court evaluates the record as a whole, it is not permitted to reweigh the 7 evidence or substitute its judgment for that of the ALJ. Ahearn v. Saul, 988 F.3d 1111, 1115 (9th 8 Cir. 2021). The ALJ is tasked with evaluating testimony, resolving conflicts in the medical 9 evidence, and addressing ambiguities in the record. Smartt, 53 F.4th at 494–95. Where the 10 evidence can be interpreted in more than one rational way, the ALJ’s decision must be upheld. 11 Id. Even if the ALJ erred, reversal is not warranted unless the error affected the outcome of the 12 disability determination. Ford v. Saul, 950 F.3d 1141, 1154 (9th Cir. 2020). The party 13 challenging the ALJ’s decision bears the burden of demonstrating harmful error. Shinseki v. 14 Sanders, 556 U.S. 396, 409 (2009).

15 IV. DISCUSSION 16 A. The ALJ Did Not Err in Evaluating Medical Evidence 17 Under regulations applicable to this case, the ALJ is required to articulate the 18 persuasiveness of each medical opinion, specifically with respect to whether the opinions are 19 supported and consistent with the record. 20 C.F.R. § 404.1520c(a)–(c). These findings must be 20 supported by substantial evidence. Woods v. Kijakazi, 32 F.4th 785, 792 (9th Cir. 2022). 21 Plaintiff argues that the ALJ erred in evaluating Dr. Lead Eric M. Abelgas’s medical 22 opinion. The ALJ considered the opinion of Dr. Abelgas and discounted it as (1) unsupported by 23 his exam findings and (2) inconsistent with record, and (3) inconsistent with Plaintiff’s reported 1 activities. AR at 30. Plaintiff argues that the ALJ “erroneously rejected Plaintiff’s treating 2 source’s opinion by relying on a gross mischaracterization of Plaintiff’s daily living activities.” 3 (Dkt. # 11 at 5.) 4 Plaintiff incorrectly emphasizes the treating relationship between himself and Dr.

5 Abelgas, citing pre-2017 caselaw to argue that “[n]ormally, [t]he opinion of a treating physician 6 is given deference because he is employed to cure and has a greater opportunity to know and 7 observe the patient as an individual.” (Dkt. # 7 at 13 (quoting Morgan v. Comm’r, 169 F.3d 595, 8 600 (9th Cir. 1999)) (internal quotation marks omitted).) Because Plaintiff applied for disability 9 benefits after March 27, 2017, revised regulations apply. 20 C.F.R. § 404.1520c. While the 10 treating relationship is still a factor that ALJs may consider, under the revised regulations there is 11 not an inherent persuasiveness to any source — consistency and supportability are the most 12 important factors. Woods v. Kijakazi, 32 F.4th 785, 791 (9th Cir. 2022); 20 C.F.R. § 13 404.1520c(c)(3). 14 Even if Plaintiff’s argument was correct, the ALJ’s unchallenged findings that Dr.

15 Abelgas’s opinion was unsupported by his exam findings and inconsistent with Dr. Cruz’s medical 16 notes would be sufficient to uphold the ALJ’s reasoning. See Woods, 32 F.4th at 792–94 & n.4 17 (consistency and supportability constitute two distinct factors that should be treated separately); 18 Carmickle v. Comm’r Soc. Sec., 533 F.3d 1155, 1162 (9th Cir. 2008) (reasoning that even if an 19 ALJ errs in a portion of his reasoning, such error is harmless where “the ALJ’s remaining 20 reasoning and ultimate credibility determination were adequately supported by substantial 21 evidence in the record.” (emphasis in original)).

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Chase v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chase-v-commissioner-of-social-security-wawd-2025.