Garcia v. Saul

CourtDistrict Court, S.D. California
DecidedMay 1, 2020
Docket3:18-cv-02541
StatusUnknown

This text of Garcia v. Saul (Garcia v. Saul) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. Saul, (S.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 BRIAN G., Case No.: 18-cv-2541-BAS-AGS 12 Plaintiff, REPORT AND RECOMMENDATION ON SUMMARY JUDGMENT 13 v. MOTIONS 14 Andrew M. SAUL, Commissioner of Social Security, 15

16 Defendant.

18 The Social Security Administration ruled that claimant was not disabled from about 19 2014 to 2017. And it discounted a surgeon’s letter supporting disability, believing that the 20 surgeon didn’t treat claimant during the relevant time frame. But the SSA was wrong. The 21 surgeon’s care took place during the exact period at issue. Given the importance of that 22 treating doctor’s opinion, this case should be remanded to consider it. 23 BACKGROUND 24 Claimant Brian G. was adjudicated disabled starting in 2004 due to “advanced 25 degenerative disc disease of the lumbar spine” and “morbid obesity.” (AR 16; see also 26 AR 272.) After his 2007 gastric-bypass surgery, however, Brian “lost 250 pounds.” 27 (AR 36.) Because his back condition then improved, the SSA concluded that he was no 28 longer disabled as of May 2014. (AR 68.) 1 Brian disagreed, so an Administrative Law Judge heard his case. The ALJ 2 determined that Brian had indeed seen “medical improvement” and was not disabled from 3 May 1, 2014, through the date of the ALJ’s decision, September 29, 2017. (AR 22, 24; see 4 also AR 18.) The ALJ considered the opinions of four doctors with differing views on the 5 exertional level that Brian could tolerate, as summarized below: 6 Doctor Role Exertional Level AR 7 T. Sabourin, M.D. Orthopedic Consultative Examiner Light 21-22 R. Masters, M.D. State Agency Consultant Light 21-22 8 R. Jacobs, M.D. State Agency Consultant Medium 21 9 P. Kirz, M.D. Orthopedic Consultative Examiner Heavy (full range) 22 10 The ALJ afforded the “most weight” to the opinion of Dr. Jacobs, adopting his “medium 11 exertional level” assessment. (AR 21, 23.) Also, the ALJ noted that both orthopedic 12 consultative examiners observed “exaggeration of symptoms.” (AR 19, 285, 329.) 13 The ALJ’s decision never mentions orthopedic surgeon William Tontz, Jr., who 14 treated Brian for years and had a more pessimistic view of his prognosis. (See AR 8, 14- 15 25, 72, 255-56.) At the disability hearing, Brian testified that his “surgeon” said Brian 16 “couldn’t do any meaningful work,” that he would need future surgery, and “not to do 17 anything too strenuous or lifting,” or else his “spine could collapse.” (AR 44-45.) The 18 administrative record contains similar statements from Dr. Tontz or attributed to him. 19 (AR 255-56; see also AR 76, 86.) Yet none of this evidence appears in the ALJ’s ruling. 20 Brian zeroed in on this omission while seeking review before the SSA’s Appeals 21 Council. He submitted a new letter from Dr. Tontz, which concluded that Brian had 22 “severe” back problems causing “trouble with standing, sitting, twisting, stooping, and 23 lifting.” (AR 8.) According to Dr. Tontz, Brian required “spinal fusion” surgery, and his 24 “back injury” and “complex treatments” would render him “unable to work indefin[i]tely.” 25 (Id.) 26 Although the first line of Dr. Tontz’s letter states that Brian “has been under my care 27 since 2014” (and the letter was dated 2018) (AR 8), the Appeals Council discounted this 28 1 evidence, arguing that it did “not relate to the period at issue [May 1, 2014, to 2 September 29, 2017].” (AR 2.) For this reason alone, the Council rejected Dr. Tontz’s 3 letter, and the ALJ’s decision became final. (AR 1-2.) 4 DISCUSSION 5 The only relevant issue is whether the SSA adequately considered Dr. Tontz’s 6 opinion, which was belatedly submitted to the Appeals Council. 7 A. Late-Filed Evidence Before the Appeals Council 8 As a threshold matter, Dr. Tontz’s letter is properly before this Court. “[W]hen a 9 claimant submits evidence for the first time to the Appeals Council, which considers that 10 evidence in denying review of the ALJ’s decision, the new evidence is part of the 11 administrative record, which the district court must consider . . . .” Brewes v. Comm’r of 12 Soc. Sec. Admin., 682 F.3d 1157, 1159-60 (9th Cir. 2012). 13 B. Treating-Doctor Rule in Cessation-of-Benefits Cases 14 To revoke previously awarded benefits, the SSA must conclude that the recipient 15 has made “medical improvement” and can return to work. See Attmore v. Colvin, 827 F.3d 16 872, 873 (9th Cir. 2016). For that medical-improvement determination, the SSA must 17 correctly account for a treating physician’s opinion. See Trevizo v. Berryhill, 871 F.3d 664, 18 675 (9th Cir. 2017) (explaining treating-doctor rule); 20 C.F.R. § 404.1594(b)(6) 19 (incorporating same standards for cessation-of-benefits cases as original applications). 20 Under the relevant regulation,1 a treating doctor’s opinion is given “controlling 21 weight” so long as it “is well-supported by medically acceptable clinical and laboratory 22 diagnostic techniques and is not inconsistent with the other substantial evidence in the 23 claimant’s case record.” Trevizo, 871 F.3d at 675 (alterations omitted). Even if a treating 24 25

26 27 1 After Brian filed his continuing-benefits claim, the SSA substantially changed the way it treats medical opinions. Compare 20 C.F.R. § 404.1527 (claims filed before 28 1 physician’s opinion is contradicted by another doctor, the SSA can only reject it after 2 “providing specific and legitimate reasons that are supported by substantial evidence.” Id. 3 The only reason the Appeals Council gave for rejecting Dr. Tontz’s opinion was that 4 it did “not relate to the period at issue”—May 1, 2014, to September 29, 2017. (AR 2.) But 5 Dr. Tontz wrote that Brian “has been under my care since 2014” and “was last examined” 6 on October 5, 2017. (AR 8; see AR 34, 72, 255-56.) In other words, Dr. Tontz’s opinion 7 appears to be based on years of treatment within the relevant period. Yet, even if 8 Dr. Tontz’s opinion were based entirely on Brian’s last examination on October 5, 2017— 9 six days after the period ended—it would still “relate” to the period at issue. “Medical 10 evaluations made after the expiration of a claimant’s insured status are relevant to an 11 evaluation of the preexpiration condition.” Taylor v. Comm’r of Soc. Sec. Admin., 659 F.3d 12 1228, 1232 (9th Cir. 2011); see also Smith v. Bowen, 849 F.2d 1222, 1224-25 (9th Cir. 13 1988) (holding that three doctors’ medical evaluations, occurring some three to nine years 14 after the expiration of the insured status, were “relevant to an evaluation of the 15 pre-expiration condition”). So the SSA’s sole reason for rejecting Dr. Tontz’s opinion was 16 wrong. 17 C. Harmless-Error Analysis 18 “Even when the ALJ commits legal error, we uphold the decision where that error is 19 harmless.” Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1099 (9th Cir. 2014). 20 An error is harmless when it is “inconsequential to the ultimate nondisability 21 determination,” or when “the agency’s path may reasonably be discerned, even if the 22 agency explains its decision with less than ideal clarity.” Id. (alterations and citations 23 omitted).

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Garcia v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-saul-casd-2020.