HARKNESS v. SAUL

CourtDistrict Court, E.D. Pennsylvania
DecidedJune 15, 2020
Docket5:19-cv-05245
StatusUnknown

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

Bluebook
HARKNESS v. SAUL, (E.D. Pa. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LINDA HARKNESS, : Plaintiff, : CIVIL ACTION : v. : : COMMISSIONER OF SOCIAL : No. 19-5245 SECURITY, : Defendant. :

MEMORANDUM OPINION

TIMOTHY R. RICE June 15, 2020 U.S. MAGISTRATE JUDGE

Plaintiff Linda Harkness alleges the Administrative Law Judge (“ALJ”) erred in denying her application for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”) in several ways, including that the limitations in the Residual Functional Capacity (RFC) assessment1 are not supported with substantial evidence. Pl. Br. (doc. 12) at 10. Because the ALJ failed to support the RFC’s mental limitations with substantial evidence, I remand the case for additional consideration.2 Harkness filed for benefits based on a combination of physical and mental impairments in March 2017. R. at 128. Her claims on appeal, however, focus solely on her mental impairments. Pl. Br. at 9-10. At her ALJ hearing, Harkness explained that she suffers from auditory hallucinations. R. at 17-18. The voices she hears fuel paranoia by telling her those around her

1 A claimant’s RFC reflects “the most [she] can still do [in a work setting] despite [her] limitations.” 20 C.F.R. §§ 404.1545(a), 416.945(a).

2 Harkness consented to my jurisdiction on December 20, 2019 (doc. 9), pursuant to 28 U.S.C. § 636(c), Fed. R. Civ. P. 72, Local Rule 72.1, and Standing Order, In re Direct Assignment of Social Security Appeal Cases to Magistrate Judges (Pilot Program) (E.D. Pa. Sept. 4, 2018). See also Roell v. Withrow, 538 U.S. 580, 584 (2003) (consent to Magistrate Judge jurisdiction can be inferred from failure to object after notice and opportunity). plan to hurt her and instructing her to hurt them first. Id. She testified the voices commanded her to use a hand scanner to hit her colleagues when she worked in an Amazon warehouse, stab her colleagues when she worked at a Crayola factory, and swerve her car into others when she drove, although she had never carried out their instructions. Id. at 64-65. She testified that she carries a knife in her purse and sleeps with a knife next to her bed. Id. at 68. Although Harkness was able to work from 2006 to 2017, she has suffered from mental illness for most of her life, including multiple hospitalizations prior to 2011 for attempted suicide. Id. at 454. The medical record documents auditory hallucinations at least as early as

April 2015, id. at 740-41, but also shows providers felt they were “manageable” when she regularly took the anti-psychotic medication Abilify, id. at 734-39. The hallucinations intensified when Harkness came under increased stress, like when she started working at the Amazon factory in September 2015. Id. at 732-33. Nonetheless, she managed to hold that job until early 2017, when she was fired for arguing with a co-worker who had complained that Harkness was talking to herself. Id. at 65. The medical records show that Harkness had temporarily stopped seeing her psychiatrist in January 2017 due to a change in insurance benefits. Id. at 416. She worked at Crayola’s crayon factory for a short period of time in 2017, but quit because she felt she would soon be compelled to hurt a co-worker. Id. at 64. The ALJ credited Harkness’s reports of auditory hallucinations, but found they were not

fully disabling based on the “longitudinal evidence of record” because medication allowed her to push her auditory hallucinations “into the background.” Id. at 25-26. According to the ALJ, because Harkness’s symptoms were “significantly decreased” with medication and therapy, she could perform routine and repetitive tasks that required judgment and occasional changes in a 2 routine work setting as long as she was limited to only occasional interaction with supervisors, colleagues, and the public. Id. at 17, 25. Based on Vocational Expert (VE) testimony, the ALJ found Harkness was able to perform the jobs she previously held in Crayola’s crayon factory and Amazon’s warehouse. Id. at 26. In support of his analysis, the ALJ noted that Harkness: (1) had never acted on her violent impulses; (2) enjoyed engaging with her family; (3) was able to perform normal activities of daily living like household chores and using her computer to access Facebook; and (4) repeatedly had mental status examinations showing normal mood and affect and a cooperative attitude. Id.

at 26. The ALJ was required to provide “substantial evidence” in support of his RFC. 42 U.S.C. § 405(g). Substantial evidence means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). Nonetheless, “[i]n making a residual functional capacity determination, the ALJ must consider all evidence before him,” and provide “some indication of the evidence which he rejects and his reason(s) for discounting such evidence.” Burnett v. Comm’r of Soc. Sec. Admin., 220 F.3d 112, 121 (3d Cir. 2000). If the ALJ fails to explain why he rejected countervailing evidence, “the reviewing court cannot tell if significant probative evidence was not credited or simply ignored.” Cotter v. Harris, 642 F.2d 700, 705 (3d Cir.1981). The ALJ failed to support his RFC with substantial evidence. He appears to have

credited Harkness’s reports of command-type auditory hallucinations that instructed her to strike co-workers. R. at 26 (“Giving the claimant all benefit of the doubt”). This is only reasonable because the medical records repeatedly corroborate her testimony on this point. See, e.g., id. at 435, 730, 733, 743. Because she was fired from Amazon for arguing with coworkers before the 3 disputes became violent and left Crayola before she could succumb to violent impulses there, the lack of violent acts is not evidence that she could return to those jobs without being driven to the cusp of violence again. The ALJ accurately noted Harkness was able to perform normal activities of daily living like household chores, using her computer, and accessing Facebook. Id. at 26. He failed to address, however, evidence that she was never able to perform these activities in normal ways. According to Harkness, she would regularly converse aloud with Facebook and the television. Id. at 76. She reported arguing with her daughter, who objected to having to listen to her mother

interact with her auditory hallucinations just like her colleagues at the factory and warehouse objected when she spoke to herself aloud there. Id. at 75, 77, 79. The ALJ found Harkness was able to return to work in the factory or warehouse because medical records showed she could push her auditory hallucinations “into the background” with medication and therapy. Id. at 25-26. At the same time some records showed Harkness could push her auditory hallucinations “into the background,” however, those same providers also noted that she still needed to shop for groceries at night when the stores were less crowded. Id. at 782-83, 788.

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Related

Roell v. Withrow
538 U.S. 580 (Supreme Court, 2003)
Kacee Chandler v. Commissioner Social Security
667 F.3d 356 (Third Circuit, 2011)
Cortes v. Commissioner of Social Security
255 F. App'x 646 (Third Circuit, 2007)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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HARKNESS v. SAUL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harkness-v-saul-paed-2020.