Grier v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedDecember 12, 2024
Docket3:24-cv-05402
StatusUnknown

This text of Grier v. Commissioner of Social Security (Grier 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
Grier 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 KENYA R.G., CASE NO. 3:24-CV-5402-DWC 11 Plaintiff, v. ORDER REVERSING AND 12 REMANDING DEFENDANT’S ACTING 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 application for disability insurance benefits (“DIB”).1 After considering the record, 17 the Court concludes the Administrative Law Judge (“ALJ”) erred in evaluating certain medical 18 opinion evidence. Had the ALJ properly considered this evidence, Plaintiff’s residual functional 19 capacity (“RFC”) may have included additional limitations, or the ultimate disability 20 determination may have changed. The ALJ’s error is, therefore, not harmless, and this matter is 21 reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the Acting 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. 2. 1 Commissioner of Social Security (“Commissioner”) for further proceedings consistent with this 2 order. 3 I. Factual and Procedural History 4 In a partially favorable decision dated August 21, 2019, an ALJ found Plaintiff had been

5 under a disability for the period of October 1, 2015, to March 2, 2019. Dkt. 7, Administrative 6 Record (“AR”) 303–41. Plaintiff filed a subsequent claim for DIB on August 26, 2019, alleging 7 disability beginning on August 17, 2019. See AR 358–39. Her application was denied at the 8 initial level and on reconsideration. AR 342, 357. She requested a hearing before an ALJ, which 9 took place on April 15, 2021. AR 264–302, 393–94. Plaintiff was represented by counsel at the 10 hearing. See AR 264. On June 2, 2021, the ALJ issued an unfavorable decision denying benefits. 11 AR 19–43. The Appeals Council denied Plaintiff’s request for review, and Plaintiff appealed to 12 this Court. AR 1–7, 460–63, 1829–31. On February 21, 2023, this Court reversed the 13 Commissioner’s decision and remanded the case for further proceedings. AR 1832–57. In 14 accordance with the Court’s order, the Appeals Council vacated the June 2021 decision and

15 remanded the case to the ALJ. AR 1858–62. 16 On November 16, 2023, the ALJ held another hearing, at which Plaintiff was also 17 represented by counsel. AR 1763–96. On March 20, 2024, the ALJ issued an unfavorable 18 decision finding Plaintiff was not under a disability from August 17, 2019, through June 30, 19 2021, the date last insured. AR 1735–62. Plaintiff again appealed to this Court. See Dkts. 1, 4. 20 II. Standard of Review 21 When reviewing the Commissioner’s final decision under 42 U.S.C. § 405(g), this Court 22 may set aside the denial of social security benefits if the ALJ’s findings are based on legal error 23 or are not supported by substantial evidence in the record. Bayliss v. Barnhart, 427 F.3d 1211,

24 1 1214 n.1 (9th Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). “We review 2 only the reasons provided by the ALJ in the disability determination and may not affirm the ALJ 3 on a ground upon which he did not rely.” Garrison v. Colvin, 759 F.3d 995, 1010 (9th Cir. 4 2014). “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue,

5 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a). 6 Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to 7 the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 8 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. 9 III. Discussion 10 Plaintiff contends the ALJ erred in evaluating certain medical opinion evidence and 11 Plaintiff’s testimony about the severity of her symptoms. Dkt. 9 at 2. She contends the proper 12 remedy for these errors is remand for an award of benefits. Id. 13 A. Medical Opinion Evidence 14 Plaintiff argues the ALJ erred in assessing medical opinion evidence from treating

15 physician Andrew Hamilton, M.D., and State agency medical consultants Merry Alto, M.D., and 16 Robert Hander, M.D. Dkt. 9 at 13. 17 The regulations regarding the evaluation of medical opinion evidence have been amended 18 for claims filed on or after March 27, 2017. See Revisions to Rules Regarding the Evaluation of 19 Medical Evidence, 82 Fed. Reg. 5844, 5867–68, 5878–79 (Jan. 18, 2017). Because Plaintiff’s 20 application was filed after that date, the new regulations apply. See 20 C.F.R. §§ 404.1520c, 21 416.920c. Under the revised regulations, ALJs “will not defer or give any specific evidentiary 22 weight, including controlling weight, to any medical opinion(s) or prior administrative medical 23 finding(s). . . .” Id. §§ 404.1520c(a), 416.920c(a). Instead, ALJs must consider every medical

24 1 opinion or prior administrative medical finding in the record and evaluate the persuasiveness of 2 each one using specific factors. Id. §§ 404.1520c(a), 416.920c(a). 3 The two most important factors affecting an ALJ’s determination of persuasiveness are 4 the “supportability” and “consistency” of each opinion. Id. §§ 404.1520c(a), 416.920c(a).

5 “Supportability means the extent to which a medical source supports the medical opinion by 6 explaining the ‘relevant . . . objective medical evidence.’” Woods v. Kijakazi, 32 F.4th 785, 791– 7 92 (9th Cir. 2022) (quoting 20 C.F.R. § 404.1520c(c)(1)); see also 20 C.F.R. § 416.920c(c)(1). 8 An opinion is more “supportable,” and thus more persuasive, when the source provides more 9 relevant “objective medical evidence and supporting explanations” for their opinion. 20 C.F.R. 10 §§ 404.1520c(c)(1), 416.920c(c)(1). “Consistency means the extent to which a medical opinion 11 is ‘consistent . . . with the evidence from other medical sources and nonmedical sources in the 12 claim.’” Woods, 32 F.4th at 792 (quoting 20 C.F.R. § 404.1520c(c)(2)); see also 20 C.F.R. § 13 416.920c(c)(2).

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