Hardin v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJune 1, 2021
Docket3:20-cv-05847
StatusUnknown

This text of Hardin v. Commissioner of Social Security (Hardin 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
Hardin v. Commissioner of Social Security, (W.D. Wash. 2021).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 CAROLYNN H., 8 Plaintiff, Case No. C20-5847 RAJ 9 v. ORDER REVERSING AND 10 REMANDING DENIAL OF 11 COMMISSIONER OF SOCIAL BENEFITS SECURITY, 12 Defendant. 13 Plaintiff seeks review of the denial of her application for Supplemental Security 14 Income Benefits. Plaintiff contends the ALJ erred by rejecting Plaintiff’s symptom 15 testimony and the opinions of Bryan Zolnikov, Ph.D. Dkt. 21, p. 1. As discussed below, 16 the Court REVERSES the Commissioner’s final decision and REMANDS the matter for 17 further administrative proceedings under sentence four of 42 U.S.C. § 405(g). 18 19 BACKGROUND 20 Plaintiff is 40 years old, has a GED, and has no past relevant work. Admin. 21 Record (“AR”) (Dkt. 19) 23, 166, 291. On March 2, 2018, Plaintiff applied for benefits, 22 alleging disability as of March 1, 2018. AR 163, 166, 264–72. Plaintiff’s application 23 was denied initially and on reconsideration. AR 161–92. 1 ALJ Allen Erickson conducted a hearing on October 1, 2019, after which he 2 issued a decision finding Plaintiff not disabled. AR 15–25, 76–130. In relevant part, 3 ALJ Johnson found Plaintiff had severe impairments of opioid use disorder, 4 posttraumatic stress disorder, and schizoaffective disorder, bipolar type. AR 17. The 5 ALJ found Plaintiff had the residual functional capacity (“RFC”) to perform the full 6 range of work with limitations in understanding and memory, sustained concentration and 7 persistence, social interaction, and adaptation. See AR 20. The Appeals Council denied 8 Plaintiff’s request for review, making the ALJ’s decision the Commissioner’s final 9 decision. AR 1–3. 10 DISCUSSION 11 12 The Court may set aside the Commissioner’s denial of Social Security benefits 13 only if the ALJ’s decision is based on legal error or not supported by substantial evidence 14 in the record as a whole. Ford v. Saul, 950 F.3d 1141, 1153–54 (9th Cir. 2020). 15 A. Plaintiff’s Symptom Testimony 16 Plaintiff contends the ALJ erred by rejecting her testimony regarding the severity 17 of her symptoms. Dkt. 21, pp. 2–6. Plaintiff testified she experiences auditory 18 hallucinations and intrusive thoughts daily despite taking medications. AR 100, 121. 19 She testified she cannot handle loud noises and men raising their voices. AR 100–01, 20 115–16. She testified crowds and public places trigger her anxiety. AR 118. Plaintiff 21 testified she does not do much because of her depression and feeling overwhelmed. AR 22 110. 23 1 The Ninth Circuit has “established a two-step analysis for determining the extent 2 to which a claimant’s symptom testimony must be credited.” Trevizo v. Berryhill, 871 3 F.3d 664, 678 (9th Cir. 2017). The ALJ must first determine whether the claimant has 4 presented objective medical evidence of an impairment that “could reasonably be 5 expected to produce the pain or other symptoms alleged.” Garrison v. Colvin, 759 F.3d 6 995, 1014–15 (9th Cir. 2014). At this stage, the claimant need only show the impairment 7 could reasonably have caused some degree of the symptoms; she does not have to show 8 the impairment could reasonably be expected to cause the severity of symptoms alleged. 9 Id. The ALJ found Plaintiff met this step. AR 20. 10 If the claimant satisfies the first step, and there is no evidence of malingering, the 11 12 ALJ may only reject the claimant’s testimony “by offering specific, clear and convincing 13 reasons for doing so. This is not an easy requirement to meet.” Garrison, 759 F.3d at 14 1014–15. 15 The ALJ erred in rejecting Plaintiff’s testimony as inconsistent with the medical 16 evidence. The ALJ first reasoned the evidence showed Plaintiff was anxious and 17 depressed, but this was not affecting her functioning to a significant degree. AR 21–22. 18 The records to which the ALJ cited note Plaintiff had normal or concrete thought process, 19 normal thought content at times, auditory hallucinations at others, normal or impaired 20 memory, sad, flat, or calm affect, anxious, normal, or labile mood, and good to poor 21 insight and judgment. See AR 931, 933, 940, 943–44, 953, 956, 964, 970–71, 982, 989– 22 90, 994–95, 999, 1003, 1011–12. Absent some more detailed discussion, the ALJ’s 23 1 reference to these records and blanket statement that they do not show functional 2 limitations is insufficient to justify rejecting Plaintiff’s testimony. See Dodrill v. Shalala, 3 12 F.3d 915, 918 (9th Cir. 1993) (“It’s not sufficient for the ALJ to make only general 4 findings; he must state which pain testimony is not credible and what evidence suggests 5 the complaints are not credible.”). 6 The ALJ further reasoned Plaintiff was stable with mental health treatment. AR 7 22. But stability with treatment does not mean one can work. An ALJ must consider the 8 medical evidence “with an understanding of the patient’s overall well-being and the 9 nature of her symptoms.” Attmore v. Colvin, 827 F.3d 872, 877 (9th Cir. 2016). Stability 10 or improvement with treatment does not always mean a claimant can function in the 11 12 workplace, as “‘[t]here can be a great distance between a patient who responds to 13 treatment and one who is able to enter the workforce.” Garrison, 759 F.3d at 1017 n.23 14 (quoting Scott v. Astrue, 647 F.3d 734, 739–40 (7th Cir. 2011)). As the records cited 15 above show, the most that can be said is that Plaintiff’s symptoms fluctuated. The ALJ 16 therefore erred in rejecting Plaintiff’s testimony based on a lack of evidence of functional 17 limitations and on a finding of stability with treatment. 18 The ALJ further erred in rejecting Plaintiff’s testimony based on a finding that she 19 was dismissed from treatment and did not seek resumption of care. The ALJ here 20 misread the record, as Plaintiff was not discharged from mental health treatment. Rather, 21 her provider warned her about missing appointments, and developed a plan that would 22 allow Plaintiff to continue receiving her medication if she was discharged from therapy 23 1 for poor attendance. See AR 940. Plaintiff nonetheless continued to receive mental 2 health counseling through August 7, 2019. See AR 929–39. 3 The ALJ next erred in rejecting Plaintiff’s testimony based on a finding that her 4 limitations were largely based on situational stressors. The ALJ based this finding on 5 testimony in which the ALJ asked Plaintiff: “[I]f you didn’t have these [family intrusions 6 and interactions] going on, would you be as uncomfortable and stressed as you – as you 7 claim to be?” AR 95. Plaintiff replied, “I don’t know.” Id. From this, the ALJ 8 concluded “[t]his indicates the claimant may feel she can work if her family is not on her 9 mind.” AR 22. That conclusion does not flow from Plaintiff’s statement or show her 10 limitations were due to situational stressors. The ALJ thus erred in rejecting Plaintiff’s 11 12 testimony on such a basis. 13 The ALJ last erred in rejecting Plaintiff’s testimony as inconsistent with her 14 activities of daily living. The ALJ reasoned Plaintiff could go to the grocery store, and 15 was able to ride on a bus to Idaho. See id. Plaintiff testified her sister-in-law takes her 16 shopping, but Plaintiff waits in the car while her sister-in-law goes through checkout. AR 17 101, 116–17. Plaintiff also testified she rode a bus to Idaho once to visit her son and 18 grandchild, but was extremely uncomfortable and would not make the trip again. AR 19 101–02.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Hardin v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hardin-v-commissioner-of-social-security-wawd-2021.