Coombs v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedOctober 4, 2024
Docket3:24-cv-05070
StatusUnknown

This text of Coombs v. Commissioner of Social Security (Coombs 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
Coombs v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 MARY C., 9 Plaintiff, Case No. C24-5070-SKV 10 v. ORDER REVERSING THE COMMISSIONER’S DECISION 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 14 Plaintiff seeks review of the denial of her application for Supplemental Security Income 15 (SSI) and Disability Insurance Benefits (DIB). Having considered the ALJ’s decision, the 16 administrative record (AR), and all memoranda of record, the Court REVERSES the 17 Commissioner’s final decision and REMANDS the matter for an award of benefits under 18 sentence four of 42 U.S.C. § 405(g). 19 BACKGROUND 20 Plaintiff was born in 1964, has a limited education, and has worked as a cashier checker 21 and caregiver. AR 3779-80. Plaintiff was last gainfully employed before July 2012. AR 3763. 22 23 1 In October 2013, Plaintiff applied for benefits, alleging disability as of October 2010.1 2 AR 179-88. Plaintiff’s applications were denied initially and on reconsideration, and Plaintiff 3 requested a hearing. AR 113-14. After conducting a hearing in January 2015, the ALJ issued a 4 decision finding Plaintiff not disabled. AR 18-37. The Appeals Council denied Plaintiff’s

5 request for review, making the ALJ’s decision the Commissioner’s final decision. AR 1-6. 6 In July 2017, Plaintiff appealed the final decision of the Commissioner to this Court, 7 which remanded the claims for further proceedings, instructing the ALJ to reevaluate the medical 8 evidence, further develop the record, reassess Plaintiff’s residual functional capacity (RFC), and 9 proceed to step five as appropriate. AR 792-802. In July 2018, after a new hearing, the ALJ 10 again found Plaintiff not disabled. AR 704-30. Plaintiff appealed the Commissioner’s final 11 decision and, while her appeal was pending, reapplied and was found disabled since April 2019. 12 AR 2871. 13 In January 2020, this Court again remanded Plaintiff’s claims with instructions for the 14 ALJ to reevaluate the overall record. AR 2993-3002. On remand, after a new hearing in

15 December 2020, where Plaintiff amended her onset date to July 2012, the ALJ reopened 16 Plaintiff’s favorable decision and concluded that Plaintiff had only been disabled since July 17 2019. AR 2868-901. 18 In March 2022, based on the parties’ stipulation, this Court remanded Plaintiff’s claims 19 again, directing the ALJ to conduct a new hearing, further develop the record, reevaluate the 20 medical source statements, lay witness evidence, and Plaintiff’s testimony, and proceed with the 21 22

23 1 The parties erroneously reference Plaintiff’s initial application date as June 2013, likely due to a scrivener’s error by the ALJ in the June 2015 nondisability determination. AR 21, 3760; see also Dkt. 13 at 2. However, the record shows that Plaintiff filed her initial applications in October 2013. AR 179-88. 1 sequential evaluation as necessary. AR 3852-54. After a new hearing in August 2023, the ALJ 2 affirmed that Plaintiff was not disabled prior to July 2019. AR 3757-93. 3 THE ALJ’S DECISION 4 Utilizing the five-step disability evaluation process,2 the ALJ found:

5 Step one: Plaintiff has not engaged in substantial gainful activity since July 2012.

6 Step two: Plaintiff has the following severe impairments: COPD, obesity, status-post colon resection for diverticulitis, degenerative disc disease, degenerative joint disease, 7 plantar fasciitis, calcaneal spurs, mood disorder, anxiety disorder.

8 Step three: These impairments do not meet or equal the requirements of a listed impairment.3 9 Residual Functional Capacity: Plaintiff can perform light work that does not require 10 standing or walking for more than 4 hours total in a workday; that does not require climbing of ladders, ropes, or scaffolds; that does not require more than occasional 11 balancing, stooping, kneeling, crouching, crawling, or climbing of ramps or stairs; that does not require concentrated exposure to vibration, pulmonary irritants, or extreme cold; 12 that does not require exposure to hazards; that consists of simple instructions; and that does not require more than superficial interaction (such as “good morning” or “here is the 13 item”).

14 Step four: Plaintiff cannot perform past relevant work.

15 Step five: As there are jobs that exist in significant numbers in the national economy that Plaintiff can perform, Plaintiff is not disabled. 16 AR 3763, 3766, 3779. 17 The ALJ’s decision addressed only the period from Plaintiff’s amended alleged disability 18 onset date of July 2012 to June 30, 2019, the day prior to the date Plaintiff became disabled after 19 reaching the advanced age category. AR 3761. This appeal followed. Dkt. 5. The parties 20 consented to proceed before the undersigned Magistrate Judge. Dkt. 3. 21

22 23 2 20 C.F.R. §§ 404.1520, 416.920. 3 20 C.F.R. Part 404, Subpart P., App. 1. 1 LEGAL STANDARDS 2 Under 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of social 3 security benefits when the ALJ’s findings are based on harmful legal error or not supported by 4 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 (9th Cir.

5 2005). As a general principle, an ALJ’s error may be deemed harmless where it is 6 “inconsequential to the ultimate nondisability determination.” Molina v. Astrue, 674 F.3d 1104, 7 1115 (9th Cir. 2012) (cited sources omitted). The Court looks to “the record as a whole to 8 determine whether the error alters the outcome of the case.” Id. 9 Substantial evidence is “more than a mere scintilla. It means—and means only—such 10 relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” 11 Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (cleaned up); Magallanes v. Bowen, 881 F.2d 12 747, 750 (9th Cir. 1989). The ALJ is responsible for evaluating symptom testimony, resolving 13 conflicts in medical testimony, and resolving any other ambiguities that might exist. Andrews v. 14 Shalala, 53 F.3d 1035, 1039 (9th Cir. 1995). While the Court is required to examine the record

15 as a whole, it may neither reweigh the evidence nor substitute its judgment for that of the 16 Commissioner. Thomas v. Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When the evidence is 17 susceptible to more than one rational interpretation, it is the Commissioner’s conclusion that 18 must be upheld. Id. 19 DISCUSSION 20 Plaintiff argues the ALJ erred by misevaluating the medical evidence, lay witness 21 statements, and Plaintiff’s testimony; resulting in a flawed RFC assessment and erroneous step 22 five determination. Plaintiff further contends that the proper remedy is to remand for an award 23 1 of benefits. Dkt. 13. The Commissioner argues the ALJ’s decision is free of harmful legal error, 2 supported by substantial evidence, and should be affirmed. Dkt. 17. 3 A. The ALJ Erred in Evaluation of the Medical Evidence 4 Because Plaintiff applied for benefits before March 27, 2017, prior regulations apply to

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Coombs v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coombs-v-commissioner-of-social-security-wawd-2024.