Fletcher-Silvas v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 15, 2025
Docket3:23-cv-06177
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. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 LYNNE F.-S., Case No. 3:23-cv-06177-TLF 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S ACTING COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, FOR ADDITIONAL PROCEEDINGS 10 Defendant. 11 12 Plaintiff filed this action pursuant to 42 U.S.C. § 405(g) for judicial review of 13 defendant’s denial of plaintiff’s application for disability insurance benefits (“DIB”). 14 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule 15 MJR 13, the parties have consented to have this matter heard by the undersigned 16 Magistrate Judge. Dkt. 5. Plaintiff challenges the Administrative Law Judge’s (“ALJ”) 17 decision finding that plaintiff was not disabled. Dkt. 8, Complaint. 18 Plaintiff was previously found to be disabled from May 23, 2014 through October 19 31, 2015. AR 115-30. 20 In August 2017 plaintiff filed an application for DIB alleging a disability onset date 21 of March 26, 2016. AR 15. The application was denied initially and upon 22 reconsideration, and on Marsh 28, 2019 a hearing was held before ALJ Rebecca Jones. 23 AR 61-109. On May 24, 2019, ALJ Jones issued a decision finding plaintiff not to be 24 disabled. AR 13-34. The Appeals Council declined the request for review and plaintiff 1 filed an appeal to this Court. AR 1-6. 2 On November 2, 2019 the Honorable Mary Alice Theiler reversed the ALJ’s 3 decision and remanded the claim for a new hearing. AR 838-53. On June 1, 2023 a 4 second hearing was held before ALJ Allen Erickson. AR 758-805. On August 28, 2023

5 ALJ Erickson issued a decision finding plaintiff not to be disabled. AR 730-57. The 6 Appeals Council declined the request for review and plaintiff filed this appeal. 7 The ALJ determined plaintiff’s date last insured to be December 31, 2019. AR 8 736. The ALJ found plaintiff to have the following severe impairments: “cervical spine 9 degenerative disc disease and degenerative joint disease, fibromyalgia, status-post 10 bilateral knee surgeries, and obesity.” AR 736. As a result, the ALJ determined plaintiff 11 had the residual functional capacity (“RFC”) to perform light work as defined in 20 CFR 12 404.1567(b) with the following additional restrictions: “she is able to occasionally climb 13 ladders, ropes, or scaffolds and occasional to crawl; able to occasionally reach 14 overhead bilaterally, and able to tolerate occasional exposure to vibration and to

15 extreme cold temperatures.” AR 742. 16 DISCUSSION 17 The parties agree that the ALJ committed harmful error. Dkt. 23. The issue 18 before the Court is limited to whether the proper remedy would be a remand for award 19 of benefits, or a remand for further proceedings. 20 1. Whether the Court should reverse with a direction to award benefits. 21 “‘The decision whether to remand a case for additional evidence, or simply to 22 award benefits[,] is within the discretion of the court.’” Trevizo v. Berryhill, 871 F.3d 664, 23 682 (9th Cir. 2017) (quoting Sprague v. Bowen, 812 F.2d 1226, 1232 (9th Cir. 1987)). If

24 1 an ALJ makes an error and the record is uncertain and ambiguous, the court should 2 remand to the agency for further proceedings. Leon v. Berryhill, 880 F.3d 1041, 1045 3 (9th Cir. 2017). Likewise, if the court concludes that additional proceedings can remedy 4 the ALJ’s errors, it should remand the case for further consideration. Revels, 874 F.3d

5 at 668. 6 The Ninth Circuit has developed a three-step analysis for determining when to 7 remand for a direct award of benefits. Such remand is generally proper only where 8 “(1) the record has been fully developed and further administrative proceedings would serve no useful purpose; (2) the ALJ has failed 9 to provide legally sufficient reasons for rejecting evidence, whether claimant testimony or medical opinion; and (3) if the improperly 10 discredited evidence were credited as true, the ALJ would be required to find the claimant disabled on remand.” 11 Trevizo, 871 F.3d at 682-83 (quoting Garrison v. Colvin, 759 F.3d 995, 1020 (9th 12 Cir. 2014)). 13 The Ninth Circuit emphasized in Leon that even when each element is satisfied, 14 the district court still has discretion to remand for further proceedings or for award of 15 benefits. Leon, 80 F.3d at 1045. 16 “Except in rare circumstances,” the district court should “remand to the agency 17 for additional investigation or explanation.” Treichler v. Comm’r of Soc., Sec. Admin., 18 775 F.3d 1090, 1099 (9th Cir. 2014). The Ninth Circuit emphasized in Leon that even 19 when each element or the review concerning the appropriate remedy on remand is 20 satisfied, the district court still has discretion to remand for further proceedings or for 21 award of benefits. Leon, 80 F.3d at 1045; see also Burrell v. Colvin, 775 F.3d 1133, 22 1141-1142 (9th Cir. 2014) (even assuming all three elements of the criteria for deciding 23 the remedy were satisfied, the Ninth Circuit Court of Appeals found the record as a 24 1 whole created serious doubt about whether the plaintiff was disabled; remand for award 2 of benefits was therefore unwarranted). 3 Here, plaintiff asks that the Court remand for an award of benefits based on the 4 ALJ’s errors in evaluating the medical opinion evidence and plaintiff’s subjective

5 testimony. Dkt. 24. Additionally, plaintiff argues that the ALJ improperly miscalculated 6 plaintiff’s date last insured and erred by failing to adjudicate the entire relevant time 7 period. Id. at 2-4. 8 A. Whether the ALJ properly calculated the date last insured 9 The parties disagree as to whether the record is fully developed; defendant 10 argues that it is unclear whether the ALJ failed to adjudicate the time period between 11 January 1, 2020 and December 31, 2020 and further administrative proceedings could 12 serve a useful purpose in clarifying this issue, and plaintiff argues that the ALJ’s 13 erroneous calculation of the date last insured does not require remand for a new 14 hearing because the calculation is fairly simple and indisputable. Dkt. 23 at 4-5; Dkt. 24

15 at 2-4. 16 Defendant points to the fact that the record contains conflicting references to the 17 date last insured, citing a certified earning record dated July 25, 2022 that lists “DIS DLI: 18 12/19” (AR 29) and a Disability Determination Explanation dated December 5, 2017 that 19 lists “DLI 12/31/2020” (AR 143). Dkt. 23 at 4. Defendant also points to multiple 20 instances in the decision where the ALJ discussed records between January 1, 2020 21 and December 31, 2020. Id. 22 Plaintiff replies that the document dated July 25, 2022 failed to adjust the date 23 last insured to account for the ‘disability freeze’ plaintiff was entitled to for the period she

24 1 was previously found to be disabled, from May 23, 2014 to October 31, 2015. Dkt. 24 at 2 3.

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Bluebook (online)
Fletcher-Silvas v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fletcher-silvas-v-commissioner-of-social-security-wawd-2025.