Defferding v. Commissioner of Social Security

District Court, W.D. Washington·Decided July 12, 2024·No. 2:24-cv-00251·Unknown

Opinion

UNITED STATES DISTRICT COURT AT SEATTLE ANNE D., Plaintiff, CASE NO. C24-251-BAT v. ORDER REVERSING AND COMMISSIONER OF SOCIAL SECURITY, Defendant.

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

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

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

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

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

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

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

Free access — add to your briefcase to read the full text and ask questions with AI

Defferding v. Commissioner of Social Security, (W.D. Wash. 2024).

Defferding v. Commissioner of Social Security (Defferding v. Commissioner of Social Security) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Kanika Revels v. Nancy Berryhill
874 F.3d 648 (Ninth Circuit, 2017)
Karen Lambert v. Andrew Saul
980 F.3d 1266 (Ninth Circuit, 2020)
Leslie Woods v. Kilolo Kijakazi
32 F.4th 785 (Ninth Circuit, 2022)
Lester v. Chater
81 F.3d 821 (Ninth Circuit, 1995)
Reddick v. Chater
157 F.3d 715 (Ninth Circuit, 1998)