Defferding v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJuly 12, 2024
Docket2:24-cv-00251
StatusUnknown

This text of Defferding v. Commissioner of Social Security (Defferding 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
Defferding 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 ANNE D., 8 Plaintiff, CASE NO. C24-251-BAT 9 v. ORDER REVERSING AND 10 REMANDING COMMISSIONER OF SOCIAL SECURITY, 11 Defendant. 12

13 Plaintiff seeks review of the denial of her application for Supplemental Security Income 14 and Disability Insurance Benefits.1 She argues the ALJ harmfully misevaluated her testimony, 15 lay witness statements, and medical opinion evidence. Dkt. 9. For the reasons below, the Court 16 REVERSES the Commissioner’s final decision and REMANDS the matter for further 17 administrative proceedings under sentence four of 42 U.S.C. § 405(g). 18 DISCUSSION 19 A. Plaintiff’s Testimony 20 The ALJ discounted Plaintiff’s testimony about the severity of her symptoms. Tr. 23-25. 21 Absent evidence of malingering, an ALJ can only reject a claimant’s testimony about the 22 severity of symptoms from a medically proven impairment by providing specific, clear, and 23

1 The parties consented to proceed before the undersigned Magistrate Judge. Dkt. 2. 1 convincing reasons which identify the non-credible testimony and explain which evidence 2 undermines it. See Lambert v. Saul, 980 F.3d 1266, 1277 (9th Cir. 2020) (cleaned up). 3 Plaintiff argues the ALJ erroneously focused on unremarkable physical examination 4 findings – which lacked probative value concerning her pain complaints – and selectively

5 summarizing the objective evidence. Dkt. 9 at 6-7. The Commissioner disagrees and asserts the 6 ALJ properly relied on inconsistencies between Plaintiff’s statements and other evidence, 7 including her activities and limited treatment. Dkt. 11 at 3-6. 8 Plaintiff testified she has long struggled with physical and mental health issues. Tr. 78- 9 92. She described constant pain due to fibromyalgia, particularly in her right foot and 10 intermittently in her arms. Tr. 78-79. Despite some relief from medication, she suffers from 11 intense nightmares and panic attacks. Tr. 85. Her employment history is marked by difficulties; 12 she left her job as a cashier at a sporting goods store twenty years ago due to an inability to stand 13 for extended periods and a lack of necessary breaks. Tr. 85-86. Over the years, her ability to 14 interact with others has deteriorated, and her mental health has worsened since 2017, with

15 notable memory issues. Tr. 86-89. Her work history is also characterized by frequent absences, 16 and she found it challenging to leave her home, even for essential tasks like grocery shopping. 17 Tr. 81, 91. When she did manage to go to the grocery store, she often became flustered, 18 struggling with tasks such as placing items in her cart or paying for purchases. Tr. 91-92. 19 Attempts at specialized treatment for PTSD proved ineffective, Tr. 90, and Plaintiff also reported 20 her father typically drove her to appointments. Tr. 92. 21 The ALJ rejected Plaintiff’s testimony about her inability to stand or sit for prolonged 22 periods due to intermittent back spasms and chronic pain highlighting Plaintiff’s limited 23 treatment and benign exam findings, noting Plaintiff was observed with normal gait and tone, 1 had full strength in all her extremities, could walk without assistance, sit comfortably, get on and 2 off the exam table without difficulty, and manipulate socks and shoes without issue. Tr. 23-24 3 (citing Tr. 885-86, 891, 1293-99, 1351-55, 1357, 1362 ). The fact some findings in the record 4 were normal does not prove Plaintiff’s chronic pain is not as severe or debilitating as she claims.

5 The ALJ has a duty to explain why findings in the record undercut a claimant’s testimony. See 6 Levin v. Schweiker, 654 F.2d 631, 634-35, esp. 634 n. 7 (9th Cir. 1981) (ALJ must make “full 7 and detailed findings of fact” supporting ultimate determination of disability); see also Beneke v. 8 Barnhart, 379 F.3d 587, 594 (9th Cir. 2004) (ALJ erred by requiring objective evidence of 9 fatigue caused, in part, by fibromyalgia, “sheer disbelief is no substitute for substantial 10 evidence.”). Here, the findings the ALJ focused on above are not mutually exclusive of 11 Plaintiff’s pain complaints and thus insufficient grounds to discount her testimony about pain. 12 Moreover, as Plaintiff highlights, Dkt. 9 at 4-6, the treatment notes the ALJ cited report 13 Plaintiff was unable to toe walk, heel walk, or tandem walk, and her feet and arms were swollen 14 and tender to touch. Tr. 1297-98. Similarly, the “relatively benign exam findings” the ALJ

15 referenced were unrelated to issues concerning Plaintiff’s foot and arm pain and did not evaluate 16 her musculoskeletal system. Tr. 1351-57, 1362-65. Occasional observations of normal gait, 17 strength, and range of motion observed during a brief treatment visit do not address Plaintiff’s 18 allegations of significant limitations standing and sitting for prolonged periods. See Loretta S. v. 19 Comm’r of Soc. Sec. Admin., 2020 WL 4559817, at *4 (D. Or. Aug. 7, 2020) (finding ALJ erred 20 by relying, in part, on treatment notes indicating “no apparent distress” to discount plaintiff’s 21 fatigue); see also Sara O. v. Comm’r of Soc. Sec. Admin., 2021 WL 4077781, at *2 (W.D. Wash. 22 Sept. 8, 2021) (finding ALJ erred, in part, by relying on normal presentation, strength, and range 23 of motion to discount plaintiff’s fatigue). 1 The ALJ also discounted Plaintiff’s testimony on the grounds there was little evidence of 2 treatment for Plaintiff’s chronic physical problems. Tr. 24. While an ALJ can discount testimony 3 that is inconsistent with the level of treatment sought, the ALJ’s evaluation must consider the 4 nature of the condition being treated. Revels v. Berryhill, 874 F.3d 648, 667 (9th Cir. 2017).

5 Here, treatment notes show Plaintiff’s medical providers reported her treatment options were 6 limited, Tr. 549, 832-33, 913, and she took multiple medications to manage her conditions. Tr. 7 1295, 1304, 1321-22, 1337-38. Plaintiff also points out that access to medical care during this 8 period was limited because of the COVID-19 pandemic. Dkt. 9 at 7. The ALJ failed to 9 meaningfully consider these factors for Plaintiff’s limited course of treatment. Social Security 10 Ruling (SSR) 16-3p, 2017 WL 5180304, at *9 (The ALJ must consider possible reasons for why 11 a claimant did not seek more treatment before rejecting her testimony). As such, substantial 12 evidence does not support the ALJ’s characterization of Plaintiff’s treatment history. 13 The ALJ also discounted Plaintiff’s testimony about panic attacks, citing evidence that 14 she had intact cognitive functioning during mental status exams and could leave home when

15 needed. Tr. 24-25. An ALJ may not reject evidence based on an inaccurate portrayal of the 16 record. Reddick v. Chater, 157 F.3d 715, 722-23 (9th Cir. 1998) (ALJ’s decision unsupported by 17 substantial evidence where “paraphrasing of record material is not entirely accurate regarding the 18 content or tone of the record.”). It is true the ALJ cited some notes reflecting intact cognitive 19 functioning, fair insight, appropriate grooming, and normal mood, behavior, thought content, and 20 judgment, (Tr.

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