Gallion v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedDecember 26, 2024
Docket3:24-cv-05273
StatusUnknown

This text of Gallion v. Commissioner of Social Security (Gallion 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
Gallion v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 JAMIE I.G., CASE NO. 3:24-CV-5273-DWC 11 Plaintiff, v. ORDER REVERSING AND 12 REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 13 SECURITY, 14 Defendant.

15 Plaintiff filed this action under 42 U.S.C. § 405(g) seeking judicial review of Defendant’s 16 denial of her applications for supplemental security income benefits (“SSI”) and disability 17 insurance benefits (“DIB”).1 After considering the record, the Court concludes the 18 Administrative Law Judge (“ALJ”) erred in her evaluation of Plaintiff’s testimony about the 19 severity of her symptoms. Had the ALJ properly considered this testimony, Plaintiff’s residual 20 functional capacity (“RFC”) may have included additional limitations, or the ultimate 21 determination of disability may have changed. The ALJ’s error is, therefore, not harmless, and 22 23 1 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties have 24 consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 3. 1 this matter is reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the 2 Commissioner of Social Security (“Commissioner”) for further proceedings consistent with this 3 order. 4 I. Factual and Procedural History

5 Plaintiff filed claims for DIB and SSI in February 2018, alleging disability beginning on 6 May 28, 2017. Dkt. 8, Administrative Record (“AR”) 294–306, 1954. Her applications were 7 denied at the initial level and on reconsideration. AR 106–07, 138–39. She requested a hearing 8 before an ALJ, which took place on October 25, 2019, with a supplemental hearing on 9 November 5, 2019. AR 57–105, 197–201. Plaintiff was represented by counsel at the hearings. 10 See AR 57, 83. On December 24, 2019, the ALJ issued an unfavorable decision denying benefits. 11 AR 26–56. The Appeals Council denied Plaintiff’s request for review. AR 1–6, 282–84. Plaintiff 12 appealed to this Court, which reversed the ALJ’s decision and remanded the case for a new 13 hearing. AR 2034–43. Another hearing took place on November 16, 2023, at which Plaintiff’s 14 counsel requested the ALJ evaluate a closed period of disability from January 1, 2017, to

15 September 30, 2021. AR 1948–74. On December 12, 2023, the ALJ found Plaintiff was not 16 under a disability either for the requested closed period or from the original alleged onset date of 17 May 28, 2017, forward. AR 1911–47. Plaintiff again appealed to this Court. See Dkts. 1, 5. 18 II. Standard of Review 19 When reviewing the Commissioner’s final decision under 42 U.S.C. § 405(g), this Court 20 may set aside the denial of social security benefits if the ALJ’s findings are based on legal error 21 or are not supported by substantial evidence in the record. Bayliss v. Barnhart, 427 F.3d 1211, 22 1214 n.1 (9th Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). “We review 23 only the reasons provided by the ALJ in the disability determination and may not affirm the ALJ

24 1 on a ground upon which he did not rely.” Garrison v. Colvin, 759 F.3d 995, 1010 (9th Cir. 2 2014). “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue, 3 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a). 4 Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to

5 the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 6 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. 7 III. Discussion 8 Plaintiff argues the ALJ erred in her consideration of Plaintiff’s testimony about the 9 severity of her symptoms, certain medical opinion evidence, lay witness testimony, and whether 10 Plaintiff met or equaled a listing, leading to an erroneous RFC and step five findings. Dkt. 13 at 11 2. She contends the proper remedy for these errors is remand for further proceedings.2 Id. at 19. 12 At step two of the sequential evaluation, the ALJ found Plaintiff had the severe 13 impairments of diabetes mellitus, asthma, mild left shoulder osteoarthritis, fibromyalgia, obesity, 14 bipolar personality disorder, and post-traumatic stress disorder (“PTSD”). AR 1917. Despite

15 these impairments, the ALJ found Plaintiff had the RFC to perform light work with certain 16 specific caveats. AR 1920. 17 A. Subjective Symptom Testimony 18 Plaintiff contends the ALJ failed to properly evaluate her testimony about the severity of 19 her symptoms. Dkt. 13 at 13. “An ALJ engages in a two-step analysis to determine whether a 20 claimant's testimony regarding subjective pain or symptoms is credible.” Garrison, 759 F.3d at 21 1014. At the first step, the ALJ determines whether the claimant has presented objective medical 22 23 2 Although Plaintiff asks that the Court credit her testimony as true, she does not argue that she is entitled to an 24 immediate award of benefits. See Dkt. 13 at 16, 19. 1 evidence of an underlying impairment that could reasonably be expected to produce the pain or 2 other symptoms alleged. Id. This evidence need not validate the severity of the alleged 3 symptoms; rather, “the medical evidence need only establish that the impairment could 4 reasonably be expected to cause some degree of the alleged symptoms.” Smith v. Kijakazi, 14

5 F.4th 1108, 1111 (9th Cir. 2021). 6 If the claimant satisfies this first step and there is no affirmative evidence of malingering, 7 “the ALJ can reject the claimant's testimony about the severity of [their] symptoms only by 8 offering specific, clear and convincing reasons for doing so.” Id. at 1112 (quoting Garrison, 759 9 F.3d at 1014–15). “This standard is ‘the most demanding required in Social Security cases.’” Id. 10 (quoting Moore v. Comm'r of Soc. Sec. Admin., 278 F.3d 920, 924 (9th Cir. 2002)). To meet this 11 standard, ALJs must “identify which testimony [they] found not credible and why.” Brown- 12 Hunter v. Colvin, 806 F.3d 487, 489 (9th Cir. 2015). 13 The Ninth Circuit has reaffirmed that the clear and convincing standard requires the ALJ 14 to make “specific finding[s]:”

15 [A]n ALJ does not provide specific, clear, and convincing reasons for rejecting a claimant's testimony by simply reciting the medical evidence in support of his or 16 her residual functional capacity determination.

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Gallion v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gallion-v-commissioner-of-social-security-wawd-2024.