Fletcher-Silvas v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedNovember 2, 2021
Docket3:20-cv-05597
StatusUnknown

This text of Fletcher-Silvas v. Commissioner of Social Security (Fletcher-Silvas 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
Fletcher-Silvas v. Commissioner of Social Security, (W.D. Wash. 2021).

Opinion

6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT TACOMA 8 LYNNE F. 9 Plaintiff, CASE NO. C20-5597-MAT 10 v. 11 ORDER RE: SOCIAL SECURITY COMMISSIONER OF SOCIAL SECURITY, DISABILITY APPEAL 12 Defendant. 13

14 Plaintiff proceeds through counsel in her appeal of a final decision of the Commissioner of 15 the Social Security Administration (Commissioner). The Commissioner denied Plaintiff’s 16 applications for Disability Insurance Benefits (DIB) after a hearing before an administrative law 17 judge (ALJ). Having considered the ALJ’s decision, the administrative record (AR), and all 18 memoranda of record, this matter is REVERSED and REMANDED for further administrative 19 proceedings. 20 FACTS AND PROCEDURAL HISTORY 21 Plaintiff was born on XXXX, 1962.1 Plaintiff has limited education and previously worked 22 as a membership solicitor, receptionist, auto parts counter person, and nurse aid. AR 28. Plaintiff 23

1 Dates of birth must be redacted to the year. Fed. R. Civ. P. 5.2(a)(2) and LCR 5.2(a)(1). 1 filed an application for DIB on August 24, 2017, alleging disability beginning May 23, 2014. 2 AR 232–33. The applications were denied at the initial level and on reconsideration. On March 3 28, 2019, the ALJ held a hearing and took testimony from Plaintiff and a vocational expert (VE).

4 AR 61–109. At the hearing, Plaintiff amended the alleged onset date to November 1, 2015.2 AR 67. 5 On May 24, 2019, the ALJ issued a decision finding Plaintiff not disabled. AR 16–30. Plaintiff 6 timely appealed. The Appeals Council denied Plaintiff’s request for review on April 16, 2020 7 (AR 1–6), making the ALJ’s decision the final decision of the Commissioner. Plaintiff appeals this 8 final decision of the Commissioner to this Court. 9 JURISDICTION 10 The Court has jurisdiction to review the ALJ’s decision pursuant to 42 U.S.C. § 405(g). 11 STANDARD OF REVIEW 12 This Court’s review of the ALJ’s decision is limited to whether the decision is in 13 accordance with the law and the findings supported by substantial evidence in the record as a

14 whole. See Penny v. Sullivan, 2 F.3d 953, 956 (9th Cir. 1993). “Substantial evidence” means more 15 than a scintilla, but less than a preponderance; it means such relevant evidence as a reasonable 16 mind might accept as adequate to support a conclusion. Magallanes v. Bowen, 881 F.2d 747, 750 17 (9th Cir. 1989). If there is more than one rational interpretation, one of which supports the ALJ’s 18 decision, the Court must uphold that decision. Thomas v. Barnhart, 278 F.3d 947, 954 (9th Cir. 19 2002). 20 21

22 2 Plaintiff previously filed a disability claim and received an unfavorable ALJ decision dated March 25, 2016. Under Chavez v. Bowen, 844 F.2d 691 (9th Cir. 1988), the ALJ considered the period from March 26, 2016, the day after the prior ALJ decision, through May 24, 2019, the date of the ALJ decision in this 23 matter. AR 16. The parties do not dispute that the ALJ accurately considered the issue of disability since March 26, 2016. Dkt. 28, at 2; Dkt. 32, at 2. 1 DISCUSSION 2 The Commissioner follows a five-step sequential evaluation process for determining 3 whether a claimant is disabled.3 See 20 C.F.R. § 405.1520 (2000).

4 At step one, the ALJ must determine whether the claimant is gainfully employed. The ALJ 5 found Plaintiff had not engaged in substantial gainful activity since the alleged onset date. AR 19. 6 At step two, the ALJ must determine whether a claimant suffers from a severe impairment. 7 The ALJ found Plaintiff has the following severe impairments: degenerative joint disc disease of 8 the bilateral knees status-post arthroscopic and total knee replacement surgeries; morbid obesity; 9 hypertension; diabetes melltius; thyroid disorder; cervical spondylosis; right carpel tunnel 10 syndrome status post-release. AR 19. The ALJ also found that the record contained evidence of 11 the following conditions that did not rise to the level of severe impairment: hyperlipidemia; mild 12 calcific tendinitis of the left shoulder; and major depressive disorder. AR 20. The ALJ further 13 found that Plaintiff had a formal diagnosis of fibromyalgia; however, the medical evidence of

14 record does not satisfy the criteria of SSR 12-2p. AR 22. 15 At step three, the ALJ must determine whether a claimant’s impairments meet or equal a 16 listed impairment. The ALJ found that Plaintiff’s impairments did not meet or equal the criteria of 17 a listed impairment. AR 22–24. 18 If a claimant’s impairments do not meet or equal a listing, the Commissioner must assess 19 residual functional capacity (RFC) and determine at step four whether the claimant has 20 demonstrated an inability to perform past relevant work. The ALJ found Plaintiff able to perform 21 light work, as defined in 20 C.F.R. § 404.1567(b), with the following limitations: 22 The claimant is able to perform work that does not require climbing ladders, ropes, or scaffolds. The claimant is able to occasionally 23

3 Under Chavez, the ALJ applied a presumption of continuing non-disability. AR 17. 1 climb ramps and stairs, and occasionally balance, stoop, kneel, crouch, and crawl. The claimant is able to perform work that does 2 not require exposure to excessive vibration or hazards as defined by the Dictionary of Occupational Titles (DOT). The claimant is able 3 to frequently bilaterally handle, finger, and feel.

4 AR 24. With that assessment, the ALJ found Plaintiff capable of performing past relevant work as 5 membership solicitor, receptionist, and auto parts counter person. AR 27–28. 6 If a claimant demonstrates an inability to perform past relevant work, or has no past 7 relevant work, the burden shifts to the Commissioner to demonstrate at step five that the claimant 8 retains the capacity to make an adjustment to work that exists in significant levels in the national 9 economy. Although the ALJ found Plaintiff capable of performing the past relevant work 10 identified above, with the assistance of a VE, the ALJ found Plaintiff capable of performing other 11 jobs, such as work as a routing clerk, production assembler, and electrical accessory assembler. 12 AR 28–29. 13 Plaintiff argues that the ALJ erred by (1) improperly evaluating the medical evidence, (2) 14 improperly evaluating Plaintiff’s testimony, and (3) improperly assessing Plaintiff’s RFC and by 15 basing her step-four and step-five findings on her erroneous RFC assessment. Plaintiff requests 16 remand for an award of benefits or, in the alternative, remand for further administrative 17 proceedings. The Commissioner argues the ALJ’s decision has the support of substantial evidence 18 and should be affirmed. 19 1. Medical Opinions 20 The regulations effective March 27, 2017, require the ALJ to articulate how persuasive the 21 ALJ finds medical opinions and to explain how the ALJ considered the supportability and 22 23 1 consistency factors.4 20 C.F.R. §§ 404

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Fletcher-Silvas v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fletcher-silvas-v-commissioner-of-social-security-wawd-2021.