Christiansen v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedMarch 2, 2023
Docket3:22-cv-05323
StatusUnknown

This text of Christiansen v. Commissioner of Social Security (Christiansen 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
Christiansen v. Commissioner of Social Security, (W.D. Wash. 2023).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 AIRAVEE C., 9 Plaintiff, Case No. C22-5323-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of her application for Supplemental Security Income 15 and Disability Insurance Benefits. Plaintiff contends the administrative law judge (“ALJ”) erred 16 in: (1) assessing the medical opinions and evidence; (2) discounting her testimony; (3) 17 discounting the lay testimony from her roommate/significant other, D.C.; 1 and (4) evaluating 18 Plaintiff’s residual functional capacity (“RFC”) and formulating the hypothetical to the 19 vocational expert (“VE”) at step five. (Dkt. # 16 at 1.) As discussed below, the Court AFFIRMS 20 the Commissioner’s final decision and DISMISSES the case with prejudice. 21

22 23 1 Because this Order contains potentially sensitive medical information, the Court refers to Plaintiff’s roommate/significant other by his initials. 1 II. BACKGROUND 2 Plaintiff was born in 1982, has a high school education and associates degree, and has 3 worked as a receptionist and administrative clerk. AR at 78, 84, 42. Plaintiff was last gainfully 4 employed in 2015. Id. at 85.

5 On September 21, 2018, Plaintiff applied for benefits, alleging disability as of January 5, 6 2016. AR at 19. Plaintiff’s applications were denied initially and on reconsideration, and Plaintiff 7 requested a hearing. Id. After the ALJ conducted hearings on July 21, 2020, November 25, 2020, 8 and March 31, 2021, the ALJ issued a decision on May 28, 2021, finding Plaintiff not disabled. 9 Id. at 19-44. 10 Using the five-step disability evaluation process,2 the ALJ found that Plaintiff has the 11 following severe impairments: diabetes, hypertension, obesity, and mental health diagnoses 12 variously diagnosed as panic disorder, generalized anxiety disorder, obsessive compulsive 13 disorder, major depressive disorder, bipolar disorder, borderline personality disorder, 14 attention-deficit hyperactivity disorder (“ADHD”), and post-traumatic stress disorder (“PTSD”).

15 AR at 22. The ALJ subsequently determined that Plaintiff retained an RFC for light work with 16 several additional postural, environmental, exertional, cognitive, and social limitations. Id. at 26. 17 Relying on the opinion of a VE who testified that an individual with such an RFC could perform 18 jobs existing in significant numbers in the economy, including hotel-motel housekeeper, office 19 helper, and small products assembler I or II, the ALJ concluded that Plaintiff was not disabled. 20 Id. at 43-44. 21 22 23 2 20 C.F.R. §§ 404.1520, 416.920. 1 As the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision is the 2 Commissioner’s final decision. AR at 1-6. Plaintiff appealed the final decision of the 3 Commissioner to this Court. (Dkt. # 7.) 4 III. LEGAL STANDARDS

5 Under 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of social 6 security benefits when the ALJ’s findings are based on legal error or not supported by substantial 7 evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 (9th Cir. 2005). As a 8 general principle, an ALJ’s error may be deemed harmless where it is “inconsequential to the 9 ultimate nondisability determination.” Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012), 10 superseded on other grounds by 20 C.F.R. § 416.920(a) (citations omitted). The Court looks to 11 “the record as a whole to determine whether the error alters the outcome of the case.” Id. 12 “Substantial evidence” is more than a scintilla, less than a preponderance, and is such 13 relevant evidence as a reasonable mind might accept as adequate to support a conclusion. 14 Richardson v. Perales, 402 U.S. 389, 401 (1971); Magallanes v. Bowen, 881 F.2d 747, 750 (9th

15 Cir. 1989). The ALJ is responsible for determining credibility, resolving conflicts in medical 16 testimony, and resolving any other ambiguities that might exist. Andrews v. Shalala, 53 F.3d 17 1035, 1039 (9th Cir. 1995). While the Court is required to examine the record as a whole, it may 18 neither reweigh the evidence nor substitute its judgment for that of the Commissioner. Thomas v. 19 Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When the evidence is susceptible to more than one 20 rational interpretation, it is the Commissioner’s conclusion that must be upheld. Id. 21 22 23 1 IV. DISCUSSION 2 A. The ALJ Did Not Err in Discounting Plaintiff’s Testimony. 3 The ALJ summarized Plaintiff’s allegations and explained that he discounted her 4 testimony based on: (1) Plaintiff’s malingering and misrepresentations; (2) Plaintiff’s

5 conservative treatment; (3) inconsistencies with Plaintiff’s activities of daily living; and (4) 6 inconsistencies with the longitudinal medical evidence. AR at 27-33. Plaintiff contends that the 7 ALJ’s reasons are not clear and convincing. See Smartt v. Kijakazi, 53 F.4th 489, 499 (9th Cir. 8 2022) (confirming that the “clear and convincing” standard continues to apply). The Court will 9 address each of Plaintiff’s arguments in turn. 10 1. Legal Standards 11 At the outset, the Court notes that affirmative evidence of symptom magnification, or 12 malingering, as there was here, relieves an ALJ from the burden of providing specific, clear, and 13 convincing reasons for discounting a claimant’s testimony. See Morgan v. Comm’r of Soc. Sec. 14 Admin., 169 F.3d 595, 599 (9th Cir. 1999) Berry v. Astrue, 622 F.3d 1228, 1235 (9th Cir. 2010)

15 (upholding finding where ALJ “pointed to affirmative evidence of malingering”). In cases 16 involving an affirmative finding of malingering, such as this one, the Court’s standard of review 17 for the ALJ’s treatment of a claimant’s testimony is for “substantial evidence,” rather than for 18 “clear and convincing” reasons. See Austin v. Saul, 818 F. App’x 725, 729 (9th Cir. 2020) 19 (discussing Reddick v. Chater, 157 F.3d 715, 720, 722 (9th Cir. 1998)); St. Clair v. Saul, 776 F. 20 App’x 447 (9th Cir. 2019) (discussing Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155, 21 1160 (9th Cir. 2008)) (adverse credibility finding need not be based on clear and convincing 22 evidence where there is affirmative evidence that the claimant is malingering). 23 1 2. Malingering and Misrepresentations 2 The ALJ here found that Plaintiff malingered when she failed to disclose to Washington 3 State Department of Social and Health Services (“DSHS”) examining physicians and 4 psychologists the full extent of her activities, which included running a rental business with her

5 significant other and doing maintenance and repairs on her home after a fire. AR at 29 (citing id.

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