Craig v. Commissioner of Social Security

District Court, W.D. Washington·Decided July 28, 2022·No. 3:22-cv-05088·Unknown

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 BRIAN C. CASE NO. 3:22-CV-5088-DWC 11 Plaintiff, ORDER AFFIRMING DEFENDANT’S 12 v. DECISION DENYING BENEFITS 13 COMMISSIONER OF SOCIAL SECURITY, 14 Defendant. 15

Plaintiff filed this action, pursuant to 42 U.S.C. § 405(g), for judicial review of the denial 16 of Plaintiff’s applications for disability insurance benefits. Pursuant to 28 U.S.C. § 636(c), Fed. 17 R. Civ. P. 73 and Local Rule MJR 13, the parties have consented to proceed before United 18 States Magistrate Judge Christel. 19 BACKGROUND 20 Plaintiff filed for Title II disability and disability insurance benefits in September 2019, 21 alleging an onset date of January 1, 2019, which he amended to April 1, 2019. AR 15, 187-88. 22 His claim was denied initially and upon reconsideration. AR 72-101. On July 23, 2021, Plaintiff 23 testified at a hearing before an Administrative Law Judge (ALJ). AR 38-71. On August 18, 2021 24 1 the ALJ issued an unfavorable decision. AR 12-37. The Appeals Council denied Plaintiff’s 2 request for review on December 17, 2021, making it the final decision of the Commissioner. AR 3 1-6; 20 C.F.R. §§ 404.981, 416.1481. 4 STANDARD

5 Pursuant to 42 U.S.C. § 405(g) this Court may set aside the Commissioner’s denial of 6 social security benefits if the ALJ’s findings are based on legal error or not supported by 7 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 8 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). However, the 9 Commissioner’s decision must be affirmed if it is supported by substantial evidence and free of 10 harmful legal error. 42 U.S.C. § 405(g); Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 11 2008). 12 Substantial evidence “is a highly deferential standard of review.” Valentine v. Comm’r of 13 Soc. Sec. Admin., 574 F.3d 685, 690 (9th Cir. 2009). The U.S. Supreme Court describes it as 14 “more than a mere scintilla.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). “It means—and

15 means only—such relevant evidence as a reasonable mind might accept as adequate to support a 16 conclusion.” Id. (internal quotations omitted). 17 DISCUSSION 18 Plaintiff argues the ALJ improperly “ignored” the opinion of a psychological consultative 19 examiner that Plaintiff “currently appears unable to obtain and maintain full time employment” 20 due to his mental impairments, failed to assess whether Plaintiff qualified for disability under 21 one of the “listings” that automatically qualify a person for benefits, and failed to incorporate 22 certain limitations into his RFC. See generally Dkt. 7. The Commissioner filed a demurrer. Dkt. 23 8.

24 1 I. Medical Evidence Regulations 2 The regulations regarding evaluation of medical evidence were amended for claims 3 protectively filed on or after March 27, 2017, such as this one. See 20 C.F.R. §§ 404.1520c(c), 4 416.920c(c). In the new regulations, the Commissioner rescinded Social Security Regulation

5 (SSR) 06-03p and broadened the definition of acceptable medical sources to include Advanced 6 Practice Registered Nurses (such as nurse practitioners), audiologists, and physician assistants. 7 See 20 C.F.R. §§ 404.1502, 416.902; 82 F. Reg. 8544; 82 F. Reg. 15263. The Commissioner also 8 clarified that all medical sources, not just acceptable medical sources, can provide evidence that 9 will be considered medical opinions. See 20 C.F.R. §§ 404.1502, 416.902; 82 F. Reg. 8544; 82 F. 10 Reg. 15263. 11 Additionally, the new regulations state the Commissioner “will no longer give any 12 specific evidentiary weight to medical opinions; this includes giving controlling weight to any 13 medical opinion.” Revisions to Rules Regarding the Evaluation of Medical Evidence, 2017 WL 14 168819, 82 Fed. Reg. 5844, at 5867-68 (Jan. 18, 2017); see also 20 C.F.R. §§ 404.1520c (a),

15 416.920c(a). Instead, the Commissioner must consider all medical opinions and “evaluate their 16 persuasiveness” based on supportability, consistency, relationship with the claimant, 17 specialization, and other factors. 20 C.F.R. §§ 404.152c(c); 416.920c(c). The most important 18 factors are supportability and consistency. 20 C.F.R. §§ 404.152c(a), (b)(2); 416.920c(a), (b)(2). 19 Although the regulations eliminate the “physician hierarchy,” deference to specific 20 medical opinions, and assigning “weight” to a medical opinion1, the ALJ must still “articulate 21

22 1 The Ninth Circuit recently held that “[t]he revised social security regulations are clearly irreconcilable 23 with our caselaw according special deference to the opinions of treating and examining physicians on account of their relationship with the claimant.” Woods v. Kijakazi, 32 F. 4th 785, 787 (9th Cir. 2022), petition for rehearing 24 pending. As a result, the Ninth Circuit concluded that the revised regulations displaced the longstanding case law 1 how [he] considered the medical opinions” and “how persuasive [he] find[s] all of the medical 2 opinions.” 20 C.F.R. §§ 404.1520c(a), (b)(1); 416.920c(a), (b)(1). The ALJ is specifically 3 required to “explain how [he] considered the supportability and consistency factors” for a 4 medical opinion. 20 C.F.R. §§ 404.1520c(b)(2); 416.920c(b)(2).

5 The supportability factor requires the ALJ to consider the relevance of the objective 6 medical evidence and the supporting explanations presented by the medical source to justify their 7 opinion. 20 C.F.R. § 416.920c(c)(1). Inversely, consistency involves a consideration of how 8 consistent a medical opinion is with the other record evidence. 20 C.F.R. § 416.920c(c)(2). 9 II. The ALJ’s Evaluation of Relevant Medical Evidence 10 Here, the ALJ found the assessments performed by State agency psychological 11 consultants were the most persuasive mental health related evidence in the record because they 12 were consistent with and supported by the medical evidence in the record as a whole. AR 28.

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