Cote v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedSeptember 4, 2025
Docket3:24-cv-05518
StatusUnknown

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

Opinion

2 3 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 4 AT TACOMA 5 DEBRA C., Case No. 3:24-cv-05518-TLF Plaintiff, 6 v. ORDER REVERSING AND REMANDING DEFENDANT’S 7 DECISION TO DENY BENEFITS LELAND DUDEK, ACTING COMMISSIONER OF SOCIAL SECURITY, 8 Defendant. 9 … 10 Plaintiff filed this action pursuant to 42 U.S.C. § 405(g) for judicial review of defendant’s 11 denial of plaintiff’s application for supplemental security income (“SSI”) and disability insurance 12 benefits (“DIB”) under 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties have consented to the jurisdiction of a Magistrate Judge. Dkt. 2. Plaintiff 13 challenges the Administrative Law Judge’s (“ALJ”) decision finding that plaintiff was not 14 disabled. Dkt. 4, Complaint. 15 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner's denial of 16 Social Security benefits if the ALJ's findings are based on legal error or not supported by substantial evidence in the record as a whole. Revels v. Berryhill, 874 F.3d 648, 654 (9th Cir. 17 2017) (internal citations omitted). Substantial evidence is “‘such relevant evidence as a 18 reasonable mind might accept as adequate to support a conclusion.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations omitted). The Court must consider the administrative 19 1 record as a whole. Garrison v. Colvin, 759 F.3d 995, 1009 (9th Cir. 2014). The Court also must weigh both the evidence that supports and evidence that does not support the ALJ’s conclusion. 2 Id. The Court may not affirm the decision of the ALJ for a reason upon which the ALJ did not 3 rely. Id. Rather, only the reasons identified by the ALJ are considered in the scope of the Court’s 4 review. Id. On January 7, 2016, Plaintiff applied for Social Security Disability Insurance Benefits 5 (“SSDI”) and Supplemental Security Income disability benefits (“SSI”), alleging a disability onset 6 date of April 1, 2013 and a date last insured of June 30, 2017. AR 435-53, AR 454. The claim was denied initially and upon reconsideration, and plaintiff requested a hearing. AR 298-301, 7 AR 307-21. 8 On May 2, 2018, ALJ Malcolm Ross found claimant not disabled. AR 15-50. Plaintiff 9 requested administrative review, which the Appeals Council (“AC”) declined. AR 420-23, AR 1- 7. Plaintiff sought judicial review, and United States Magistrate Judge Richard Creatura ordered 10 a remand for further proceedings. AR 1761-74. After a hearing on remand, on May 25, 2021, 11 ALJ Ross again found Plaintiff not disabled. AR. 1553-95. The parties filed a stipulated motion 12 for remand, and on December 22, 2021, Judge Creatura reversed and remanded for further administrative proceedings. AR 3442-46. 13 On June 13, 2022, the AC issued an order remanding the case to a different ALJ. AR 14 3455-61. ALJ Allen G. Erickson held two hearings with plaintiff, her attorney, and a VE in attendance and, on March 13, 2024, found plaintiff not disabled before November 19, 2021, but 15 disabled on that date and continued to be disabled through March 13, 2024. AR 3321-98, AR 16 3259-320. After exhausting her administrative remedies, plaintiff now seeks review of this March 17 2024 decision. Dkt. 1. ALJ Erickson found Plaintiff to have the following severe impairments: lumbar spine 18 degenerative disc disease, degenerative joint disease, and spondylolisthesis, and major 19 depressive disorder (MDD). AR 3266. The ALJ found the “claimant’s substance use is not a 1 contributing factor material to the determination of disability.” AR 3268. The ALJ determined Plaintiff had the residual functional capacity (“RFC”) to perform light work as defined in 20 2 C.F.R. 404.1567(b) and 416.967(b) except occasional climbing of ladders, ropes, and scaffolds; 3 occasional crawling; occasional exposure to vibration; occasional exposure to extreme cold 4 temperatures; an ability to understand, remember, and apply, detailed, not complex, instructions; perform predictable tasks; not in a fast passed, production type environment; 5 exposure to occasional workplace changes; and occasional interaction with the public. AR 3273. 6 Prior to the established disability onset date of November 19, 2021, the ALJ determined plaintiff could have performed the following work: Routing Clerk (DOT 222687022; light; SVP-2; 105,000 7 positions); Collator Operator (DOT 208.685-010; light; SVP-2, 33,000 positions); Parking Lot 8 Attendant (DOT 915.473-010, light, SVP-2; 25,000 positions). AR 3298. 9 DISCUSSION 10 1. Whether the ALJ harmfully erred by not conducting a two-step DAA analysis, as required under Bustamante and SSR 13-2P 11 Plaintiff argues the ALJ used the effects of Drug Addiction or Alcoholism (“DAA”) to discount 12 opinions and testimony before properly separating out the effects of DAA, as required under 13 Bustamante v. Massanari, 262 F.3d 949, 955 (9th Cir. 2001) and SSR 13-2p. Dkt. 14, at 5-8; SSR 13-2P, 78 Fed. Reg. 11939 (Feb. 20, 2013). Defendant argues the ALJ was not required to 14 determine DAA materiality because the ALJ did not find plaintiff disabled after considering her 15 substance use. Dkt. 20, at 11. 16 If substance use disorder is a material contributing factor, the Contract with America 17 Advancement Act, Pub. L. No. 104-121, Sec. 105, 110 Stat. 847 (March 29, 1996) applies, and states that “an individual shall not be considered to be disabled for purposes of [benefits under 18 Title II or XVI of the Social Security Act] if alcoholism or drug addiction would (but for this 19 subparagraph) be a contributing factor material to the Commissioner’s determination that the 1 individual is disabled.”). 42 U.S.C. §§ 423(d)(2)(C), 1382c(a)(3)(J); Sousa v. Callahan, 143 F.3d 1240, 1245 (9th Cir. 1998) (reversing and noting the district court “failed to distinguish between 2 substance abuse contributing to the disability and the disability remaining after the claimant 3 stopped using drugs or alcohol.” (emphasis in original)). 4 Under Ninth Circuit precedent, in analyzing substance abuse in a disability determination the 5 ALJ must first determine whether the claimant is disabled under the standard five-step process, including DAA. If the ALJ makes a disability finding at step one, the ALJ must conduct the five- 6 step sequence a second time to separate out the effects of DAA and determine whether the 7 plaintiff would be found disabled if they ceased using drugs or alcohol. Bustamante, 262 F.3d at 955. Moreover, SSR 13-2p requires an ALJ to determine the nature of plaintiff’s DAA, whether it 8 is medically determinable, and how it interacts with each of plaintiff’s impairments after a 9 disability has been established.1 10 Here, the ALJ found that the “claimants substance use is not a contributing factor material to 11 the determination of disability.” AR 3268. Yet the ALJ made findings to discount the medical opinions on record on the basis that plaintiff’s symptoms and impairments were intertwined with 12 or caused by substance using, including alcohol, cannabis, and opiates.

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