France v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedApril 9, 2020
Docket3:19-cv-05590
StatusUnknown

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

Opinion

5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE

7 PATRICIA F.,

8 Plaintiff, CASE NO. C19-5590-MAT

9 v. ORDER RE: SOCIAL SECURITY 10 ANDREW M. SAUL, DISABILITY APPEAL Commissioner of Social Security, 11 Defendant. 12

13 Plaintiff proceeds through counsel in her appeal of a final decision of the Commissioner of 14 the Social Security Administration (Commissioner). The Commissioner denied plaintiff’s 15 application for Disability Insurance Benefits (DIB) after a hearing before an Administrative Law 16 Judge (ALJ). Having considered the ALJ’s decision, the administrative record (AR), and all 17 memoranda of record, this matter is REMANDED for further administrative proceedings. 18 FACTS AND PROCEDURAL HISTORY 19 Plaintiff was born on XXXX, 1967.1 She completed college and obtained a Master’s 20 Degree, and previously worked as a social worker in the army. (AR 23, 46-53, 243, 469.) 21 Plaintiff protectively filed a DIB application in March 2018, alleging disability beginning 22 September 30, 2015. (AR 224.) The application was denied initially and on reconsideration. On 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 January 31, 2019, ALJ Allen Erickson held a hearing, taking testimony from plaintiff and a 2 vocational expert (VE). (AR 37-108.) On February 14, 2019, the ALJ issued a decision finding 3 plaintiff not disabled. (AR 15-24.)

4 Plaintiff timely appealed. The Appeals Council denied plaintiff’s request for review on 5 April 24, 2019 (AR 1), making the ALJ’s decision the final decision of the Commissioner. Plaintiff 6 appealed the final decision to this Court. 7 JURISDICTION 8 The Court has jurisdiction to review the ALJ’s decision pursuant to 42 U.S.C. § 405(g). 9 DISCUSSION 10 The Commissioner follows a five-step sequential evaluation process for determining 11 whether a claimant is disabled. See 20 C.F.R. §§ 404.1520, 416.920 (2000). At step one, it must 12 be determined whether a claimant is gainfully employed. The ALJ found plaintiff had not engaged 13 in substantial gainful activity since the onset date. At step two, it must be determined whether a

14 claimant suffers from a severe impairment. The ALJ found post-traumatic stress disorder (PTSD), 15 depression, and anxiety severe. He found physical impairments non-severe. Step three asks 16 whether a claimant’s impairments meet or equal a listed impairment. The ALJ found plaintiff’s 17 impairments did not meet or equal the criteria of a listing. 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 a full range of work at all exertional levels, but with nonexertional limitations. Plaintiff can 22 understand, remember, and apply detailed, but not complex, instructions while performing only 23 predictable tasks, not in a fast-paced, production type environment; have exposure to only 1 occasional, routine workplace changes; and have only occasional interaction with the general 2 public and co-workers. With that assessment, the ALJ found plaintiff unable to perform past work. 3 If a claimant demonstrates an inability to perform past relevant work, or has no past

4 relevant work, the burden shifts to the Commissioner to demonstrate at step five that the claimant 5 retains the capacity to make an adjustment to work that exists in significant levels in the national 6 economy. With the assistance of the VE, the ALJ found plaintiff capable of performing other jobs, 7 such as work as a production line solderer, electrical accessories assembler, and marker. 8 This Court’s review of the ALJ’s decision is limited to whether the decision is in 9 accordance with the law and the findings supported by substantial evidence in the record as a 10 whole. See Penny v. Sullivan, 2 F.3d 953, 956 (9th Cir. 1993). Accord Marsh v. Colvin, 792 F.3d 11 1170, 1172 (9th Cir. 2015) (“We will set aside a denial of benefits only if the denial is unsupported 12 by substantial evidence in the administrative record or is based on legal error.”) Substantial 13 evidence means more than a scintilla, but less than a preponderance; it means such relevant

14 evidence as a reasonable mind might accept as adequate to support a conclusion. Magallanes v. 15 Bowen, 881 F.2d 747, 750 (9th Cir. 1989). If there is more than one rational interpretation, one of 16 which supports the ALJ’s decision, the Court must uphold that decision. Thomas v. Barnhart, 278 17 F.3d 947, 954 (9th Cir. 2002). 18 Plaintiff argues the ALJ failed to properly evaluate medical evidence, her testimony, the 19 RFC, and step five. She requests remand for benefits or, alternatively, further proceedings. The 20 Commissioner argues the ALJ’s decision should be affirmed. 21 Medical Opinions and Evidence 22 Because plaintiff filed her claim after March 27, 2017, new regulations apply to the ALJ’s 23 evaluation of medical opinion evidence. Under the regulations, an ALJ “will not defer or give any 1 specific evidentiary weight, including controlling weight, to any medical opinion(s) or prior 2 administrative medical finding(s)[.]” 20 C.F.R. §§ 404.1520c(a), 416.920c(a).2 The ALJ must 3 articulate and explain the persuasiveness of an opinion or prior finding based on “supportability”

4 and “consistency,” the two most important factors in the evaluation. Id. at (a), (b)(1)-(2). The 5 “more relevant the objective medical evidence and supporting explanations presented” and the 6 “more consistent” with evidence from other sources, the more persuasive a medical opinion or 7 prior finding. Id. at (c)(1)-(2). The ALJ may but is not required to explain how other factors were 8 considered, as appropriate, including relationship with the claimant (length, purpose, and extent of 9 treatment relationship; frequency of examination); whether there is an examining relationship; 10 specialization; and other factors, such as familiarity with other evidence in the claim file or 11 understanding of the Social Security disability program’s policies and evidentiary requirements. 12 Id. at (b)(2), (c)(3)-(5). But see id. at (b)(3) (where finding two or more opinions/findings about 13 same issue equally supported and consistent with the record, but not exactly the same, ALJ will

14 articulate how other factors were considered). Where a single medical source provides multiple 15 opinions or findings, the ALJ conducts a single analysis and need not articulate how each opinion 16 or finding is considered individually. Id. at (b)(1). 17 The regulations applicable to cases filed before March 27, 2017 employ a hierarchy of 18 opinion evidence consistent with Ninth Circuit case law wherein, as a general matter, more weight 19 should be given to the opinion of a treating doctor than to an examining doctor, and more weight 20 to the opinion of an examining doctor than to a non-examining doctor. See Lester v.

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