Dobbs v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedAugust 29, 2023
Docket4:22-cv-00384
StatusUnknown

This text of Dobbs v. Commissioner of Social Security Administration (Dobbs v. Commissioner of Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dobbs v. Commissioner of Social Security Administration, (D. Ariz. 2023).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Michael Dobbs, No. CV-22-00384-TUC-RCC

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 On July 14, 2023, Magistrate Judge Angela M. Martinez filed a Report and 16 Recommendation ("R&R") recommending that the Court affirm the decision of the 17 Commissioner of Social Security ("Commissioner"). (Doc. 25.) The Magistrate Judge 18 informed the parties that they had 14 days to file written objections to the R&R and an 19 additional 14 days to respond. (Id. at 18.) Plaintiff filed an objection. (Doc. 27.) The 20 Commissioner responded. (Doc. 29.) 21 I. Standard of Review 22 The standard of review applied to a magistrate judge's report and recommendation 23 depends on whether a party files objections. See Thomas v. Arn, 474 U.S. 140, 149–50 24 (1985). A district court need not review "a magistrate's factual or legal conclusions, under 25 a de novo or any other standard, when neither party objects to those findings." Id. at 150. 26 If, however, a party objects, the district court "must determine de novo any part of the 27 magistrate judge's disposition that has been properly objected to. The district judge may 28 accept, reject, or modify the recommended disposition; receive further evidence; or return 1 the matter to the magistrate judge with instructions." Fed. R. Civ. P. 72(b)(3); 28 U.S.C. § 2 636(b)(1)(C). Although the district court is not required to review an issue de novo absent 3 a proper objection, the statute "does not preclude further review by the district judge, sua 4 sponte or at the request of a party, under a de novo or any other standard." Thomas, 474 5 U.S. at 154. 6 II. Magistrate Judge's Report and Recommendation1 7 a. Opinion Evidence 8 The Magistrate Judge concluded that substantial evidence supports the ALJ's 9 weighing of the medical opinions offered by Drs. Wingate, Wheeler, and Hopfenbeck. 10 (Doc. 25 at 4–10.) The Magistrate Judge examined the supportability and consistency 11 determinations the ALJ made with regard to the testimony from each of these doctors. 12 (Id.) 13 First, the Magistrate Judge reasoned the record supports the finding that Dr. 14 Wingate's opinion was inconsistent with other medical evidence. (Id. at 6 (citing several places in the record where mental health symptoms were responsive to treatment).) 15 Although Dr. Wingate opined that Plaintiff had marked limitations in performing 16 activities within a schedule, maintaining regular attendance, being punctual, maintaining 17 appropriate behavior in a work setting, and completing a normal workday and week 18 without interruptions from psychological symptoms, other medical evidence showed that 19 his symptoms had improved with treatment and he displayed a normal and appropriate 20 affect during sessions. (Id.) The Magistrate Judge also determined it was reasonable for 21 the ALJ to doubt portions of Dr. Wingate's opinion because Dr. Wingate "did not account 22 for her observation of Plaintiff's minimal effort and possible feigning of memory 23 problems . . . ." (Id.) Still, the Magistrate Judge highlighted that, to the extent the ALJ 24 discounted portions of Dr. Wingate's opinion, he articulated specific reasons other than 25 Dr. Wingate's observation that Plaintiff may have feigned memory issues. (Id.) 26 Next, the Magistrate Judge determined that substantial evidence supports the 27 1 Because there is no objection to the factual or procedural summary, the Court 28 incorporates the Magistrate Judge's recitation of the facts and only refers to them as is necessary to explain the Court's decision adopting the R&R. 1 ALJ's favoring of Dr. Wheeler's opinion, which found that limitations on Plaintiff's basic 2 work activities and overall severity of his mental impairments were only moderate. (Id. at 3 7–8.) While the Magistrate Judge acknowledged it was problematic for the ALJ to 4 highlight Dr. Wheeler's belief that Plaintiff was trying to "make his case" or "v[ie] for 5 disability," she ultimately concluded that this error was harmless. (Id. at 8.) The 6 Magistrate Judge explained "the ALJ relied primarily on other medical evidence in the 7 record showing Plaintiff's improvement with treatment, consistently stable and normal 8 mood and affect, no more than moderate deficits in mental functioning, and engagement 9 in various social and community activities." (Id.) She also observed that neither Dr. 10 Wingate nor Dr. Wheeler articulated whether or how their doubts regarding Plaintiff's 11 veracity affected their ultimate conclusions. (Id.) 12 The Magistrate Judge further concluded there is substantial evidence to support 13 the ALJ's judgment of Dr. Hopfenbeck's opinion. (Id. at 10.) Dr. Hopfenbeck opined that 14 Plaintiff meets the criteria for severe and chronic PTSD and that it is “very unlikely” that his condition will significantly improve to the level of being able to work. (Id. at 9.) The 15 Magistrate Judge explained that the ALJ relied on other medical evidence to find that Dr. 16 Hopfenbeck's examination was either based on incomplete information or otherwise 17 inconsistent with the record. (Id. at 10 (citing several places in the record that 18 contradicted Dr. Hopfenbeck's opinion).) For example, as the Magistrate Judge 19 highlighted, Plaintiff reported to Dr. Hopfenbeck that he had contemplated suicide but 20 denied suicidal thoughts during treatment. (Id. at 9.) 21 b. Symptom Testimony 22 Next, the Magistrate Judge examined the ALJ's decision to afford less weight to 23 Plaintiff's testimony regarding the severity and effect of his mental health symptoms 24 because it was inconsistent with the record. (Id. at 12–17.) The Magistrate Judge outlined 25 the various inconsistencies that the ALJ articulated in his decision. (Id. at 12–14.) She 26 then concluded that "[t]he ALJ made sufficiently specific, clear, and convincing findings 27 regarding the weight given to Plaintiff's testimony." (Id. at 16.) The Magistrate Judge 28 further considered evidence that might undermine the ALJ's conclusion but found that 1 none of it "upend[ed] the substantial evidence supporting the ALJ's conclusion." (Id. at 2 17.) 3 III. Plaintiff's Objection 4 Plaintiff filed an Objection in which he argues that the Magistrate Judge 5 incorrectly applied the standard to conclude there is substantial evidence to support the 6 ALJ's assessment of the medical opinions. (Doc. 27 at 1–2.) Specifically, Plaintiff argues 7 that any evidence his symptoms had improved is insufficient to contradict the conclusion 8 that he is disabled. (Id. at 2.) 9 Furthermore, Plaintiff urges the Court not to consider the fact that Dr. Wingate 10 failed to explain whether she accounted for her observation that Plaintiff feigned memory 11 problems before she concluded that he had marked limitations in overall functioning 12 because Dr. Wingate did not find Plaintiff had marked limitations in memory. (Id.) 13 Relatedly, Plaintiff argues the Magistrate Judge incorrectly concluded that any error in 14 relying on the fact that Drs. Wingate and Wheeler questioned Plaintiff's truthfulness was harmless. (Id.

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Bluebook (online)
Dobbs v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dobbs-v-commissioner-of-social-security-administration-azd-2023.