Fletcher v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedFebruary 13, 2020
Docket2:19-cv-00857
StatusUnknown

This text of Fletcher v. Commissioner of Social Security (Fletcher 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 v. Commissioner of Social Security, (W.D. Wash. 2020).

Opinion

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5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT TACOMA 8 DANNY E. F., 9 CASE NO. 2:19-CV-0857-DWC Plaintiff, 10 ORDER REVERSING AND v. REMANDING DEFENDANT’S 11 DECISION TO DENY BENEFITS COMMISSIONER OF SOCIAL SECURITY, 12

Defendant. 13

14 Plaintiff filed this action, pursuant to 42 U.S.C. § 405(g), for judicial review of 15 Defendant’s denial of Plaintiff’s applications for supplemental security income (“SSI”). Pursuant 16 to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73 and Local Rule MJR 13, the parties 17 have consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 4. 18 After considering the record, the Court concludes the Administrative Law Judge (“ALJ”) 19 erred when she improperly discounted Dr. Kathleen Anderson’s opinion and the portion of Dr. 20 Diane Fligstein’s opinion regarding Plaintiff’s ability to respond to usual stressors encountered 21 in a competitive work environment. The ALJ’s error is therefore harmful, and this matter is 22 reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the Commissioner of 23 24 1 the Social Security Administration (“Commissioner”) for further proceedings consistent with this 2 Order. 3 FACTUAL AND PROCEDURAL HISTORY 4 On September 21, 2015, Plaintiff filed an application for SSI, alleging disability as of

5 February 1, 2013. See Dkt. 10, Administrative Record (“AR”) 15. The application was denied 6 upon initial administrative review and on reconsideration. See AR 15. A hearing was held before 7 ALJ Mary Gallagher Dilley on December 13, 2017. See AR 15. In a decision dated July 3, 2018, 8 the ALJ determined Plaintiff to be not disabled. See AR 29. Plaintiff’s request for review of the 9 ALJ’s decision was denied by the Appeals Council, making the ALJ’s decision the final decision 10 of the Commissioner. See AR 13; 20 C.F.R. § 404.981, § 416.1481. 11 In the Opening Brief, Plaintiff maintains the ALJ erred by improperly discounting the 12 opinions of Drs. Fligstein and Anderson. Dkt. 14. 13 STANDARD OF REVIEW 14 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of

15 social security benefits if the ALJ’s findings are based on legal error or not supported by 16 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 17 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). 18 DISCUSSION 19 I. Whether the ALJ properly considered the medical opinion evidence.

20 Plaintiff asserts the ALJ improperly discounted the opinions of Drs. Fligstein and 21 Anderson. 22 In assessing an acceptable medical source, an ALJ must provide “clear and convincing” 23 reasons for rejecting the uncontradicted opinion of either a treating or examining physician. 24 1 Lester v. Chater, 81 F.3d 821, 830 (9th Cir. 1995) (citing Pitzer v. Sullivan, 908 F.2d 502, 506 2 (9th Cir. 1990)); Embrey v. Bowen, 849 F.2d 418, 422 (9th Cir. 1988). When a treating or 3 examining physician’s opinion is contradicted, the opinion can be rejected “for specific and 4 legitimate reasons that are supported by substantial evidence in the record.” Lester, 81 F.3d at

5 830-831 (citing Andrews v. Shalala, 53 F.3d 1035, 1043 (9th Cir. 1995)); Murray v. Heckler, 6 722 F.2d 499, 502 (9th Cir. 1983). The ALJ can accomplish this by “setting out a detailed and 7 thorough summary of the facts and conflicting clinical evidence, stating his interpretation 8 thereof, and making findings.” Reddick v. Chater, 157 F.3d 715, 725 (9th Cir. 1998) (citing 9 Magallanes v. Bowen, 881 F.2d 747, 751 (9th Cir. 1989)). 10 A. Dr. Fligstein 11 Dr. Fligstein, a Washington State Department of Social and Health Services (“DSHS”) 12 psychological consultant, opined Plaintiff could carry out complex tasks but his concentration, 13 persistence, or pace would wax/wane based on his interests in the tasks and the severity of his 14 psychiatric symptoms. AR 96. She opined Plaintiff should work with minimal to no public

15 contact. AR 96. Dr. Fligstein opined that because Plaintiff has a long history of homelessness 16 and lack of sustained work, Plaintiff “would have moderate difficulty responding to the usual 17 stressor [sic] encountered in a competitive work environment.” AR 97. 18 The ALJ analyzed Dr. Fligstein’s opinion in two segments. First, she addressed Dr. 19 Fligstein’s opinion regarding Plaintiff’s concentration. Next, she discussed Dr. Fligstein’s 20 opinion regarding Plaintiff’s ability to respond to the usual stressors encountered in a 21 competitive work environment. 22 23

24 1 1. Plaintiff’s concentration 2 Regarding Dr. Fligstein’s opinion on Plaintiff’s concentration, the ALJ gave it partial 3 weight, saying: 4 The undersigned gives partial weight to the opinion of Dr. Fligstein because it is somewhat consistent with the longitudinal evidence. However, the undersigned 5 does not agree that the claimant’s concentration would wax and wane based on the claimant’s interests. (1) This part of Dr. Fligstein’s opinion is inconsistent 6 with the fact that providers have typically observed the claimant as alert/oriented at medical appointments. Apart from some problems with Serial 7’s and recalling 7 items after delay, the claimant has typically demonstrated no cognitive deficits on testing. These benign findings do not corroborate Dr. Fligstein’s opinion of 8 waxing and waning concentration. (2) Dr. Fligstein’s opinion is also inconsistent with the claimant’s own report that he has no issues with paying attention and (3) 9 that the claimant is not taking any psychotropic medication.

10 AR 25 (citations omitted) (numbering added).

11 First, the ALJ discounted the portion of Dr. Fligstein’s opinion regarding Plaintiff’s 12 concentration because it is inconsistent with Plaintiff’s mostly normal testing and with how 13 Plaintiff’s providers typically observed him as alert and oriented. AR 25. An inconsistency with 14 the medical evidence may serve as a specific, legitimate reason for discounting limitations 15 assessed by a physician. See 20 C.F.R. § 404.1527(c)(4).

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Fletcher v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fletcher-v-commissioner-of-social-security-wawd-2020.