Harris v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedAugust 26, 2025
Docket2:24-cv-02002
StatusUnknown

This text of Harris v. Commissioner of Social Security (Harris 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
Harris v. Commissioner of Social Security, (W.D. Wash. 2025).

Opinion

1 2 3 4

5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 CAROLYN H., 9 Plaintiff, Case No. C24-2002-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of her applications for Supplemental Security Income 15 and Disability Insurance Benefits. Plaintiff contends that the administrative law judge (“ALJ”) 16 erred by misevaluating the medical opinions and Plaintiff’s testimony. (Dkt. # 13.) Plaintiff seeks 17 remand for an award of benefits. (Id. at 18-19.) The Commissioner filed a response arguing that, 18 although the ALJ erred, remand for further proceedings is the proper remedy. (Dkt. # 18.) 19 Plaintiff filed a reply. (Dkt. # 19.) Having considered the ALJ’s decision, the administrative 20 record (“AR”), and the parties’ briefing, the Court REVERSES the Commissioner’s final 21 22 23 1 decision and REMANDS the matter for an award of benefits under sentence four of 42 U.S.C. 2 § 405(g).1 3 II. BACKGROUND 4 Plaintiff was born in February 1965, has at least a high school education, and has worked

5 as a customer service representative supervisor. AR at 1081-82. Plaintiff was last gainfully 6 employed in July 2015. Id. at 1067. 7 In December 2016, Plaintiff applied for benefits, alleging disability as of July 2015. AR 8 at 15. Plaintiff’s applications were denied initially and on reconsideration, and Plaintiff requested 9 a hearing. Id. After the ALJ conducted a hearing in August 2018, the ALJ issued a decision 10 finding Plaintiff not disabled. Id. Plaintiff appealed the finding to this Court, which affirmed, and 11 subsequently to the Ninth Circuit, which remanded for further proceedings. While her appeal 12 was pending, Plaintiff filed a new application for benefits and was found disabled as of October 13 25, 2019. Id. at 1263. The Appeals Council consolidated her two cases and on remand the ALJ 14 considered whether Plaintiff had been disabled for a closed period from July 1, 2015, through her

15 date last insured, October 24, 2019. Id. at 1064-67. 16 Using the five-step disability evaluation process,2 the ALJ found, in pertinent part, 17 Plaintiff has the severe impairments of status-post acute myocardial infarction and pulmonary 18 embolism, degenerative disc disease, osteoarthritis, fibromyalgia/chronic pain syndrome, 19 migraines, obesity, depressive disorder, anxiety disorder, and status-post substance 20 abuse/addiction disorder. AR at 1067. She had the residual functional capacity (“RFC”) to 21 perform light work with some additional exertional and environmental limitations; she could 22

23 1 The parties consented to proceed before the undersigned Magistrate Judge. (Dkt. # 3.)

2 20 C.F.R. §§ 404.1520, 416.920. 1 perform well learned simple, routine and complex tasks; and she could have only incidental 2 contact with the public and frequent interactions with coworkers. Id. at 1072. Finding Plaintiff 3 could perform jobs available in significant numbers in the national economy, the ALJ concluded 4 she was not disabled. Id. at 1082-83.

5 As the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision is the 6 Commissioner’s final decision. AR at 1210. Plaintiff appealed the final decision of the 7 Commissioner to this Court. (Dkt. # 5.) 8 III. LEGAL STANDARDS 9 Under 42 U.S.C. § 405(g), this Court may overturn the Commissioner’s denial of social 10 security benefits if the ALJ’s decision rests on legal error or is not supported by substantial 11 evidence. Smartt v. Kijakazi, 53 F.4th 489, 494 (9th Cir. 2022). Substantial evidence is defined 12 as “such relevant evidence as a reasonable mind might accept as adequate to support a 13 conclusion.” Biestek v. Berryhill, 587 U.S. 97, 102-03 (2019) (cleaned up). In applying this 14 standard, the Court must consider the record as a whole to determine whether it contains

15 sufficient evidence to support the ALJ’s findings. Id. 16 Although the Court evaluates the record as a whole, it is not permitted to reweigh the 17 evidence or substitute its judgment for that of the ALJ. Ahearn v. Saul, 988 F.3d 1111, 1115 (9th 18 Cir. 2021). The ALJ is tasked with evaluating testimony, resolving conflicts in the medical 19 evidence, and addressing ambiguities in the record. Smartt, 53 F.4th at 494-95. Where the 20 evidence can be interpreted in more than one rational way, the ALJ’s decision must be upheld. 21 Id. Even if the ALJ erred, reversal is not warranted unless the error affected the outcome of the 22 disability determination. Ford v. Saul, 950 F.3d 1141, 1154 (9th Cir. 2020). The party 23 1 challenging the ALJ’s decision bears the burden of demonstrating harmful error. Shinseki v. 2 Sanders, 556 U.S. 396, 409 (2009). 3 IV. DISCUSSION 4 A. Proper Remedy is Remand for Benefits

5 Plaintiff argues the ALJ’s misevaluation of Dr. Cline’s opinion and her testimony 6 compels an award of benefits. (Dkt. # 19 at 9-10.) Remand for an award of benefits “is a rare and 7 prophylactic exception to the well-established ordinary remand rule.” Leon v. Berryhill, 880 F.3d 8 1041, 1044 (9th Cir. 2017). The Ninth Circuit has established a three-step framework for 9 deciding whether a case may be remanded for an award of benefits: (1) the ALJ must have failed 10 to provide legally sufficient reasons for rejecting evidence; (2) the record must be fully 11 developed, leaving no useful purpose for further administrative proceedings; and (3) if the 12 improperly discredited evidence were credited as true, the ALJ would be required to find the 13 claimant disabled on remand. See Garrison v. Colvin, 759 F.3d 995, 1020 (9th Cir. 2014). Even 14 if all three prongs of the test are satisfied, the Court has flexibility to remand for further

15 proceedings “when the record as a whole creates serious doubt as to whether the claimant is, in 16 fact, disabled within the meaning of the Social Security Act.” Id. at 1021. 17 In this case, all three prongs of the Garrison test are satisfied. There is no dispute that the 18 ALJ failed to provide legally sufficient reasons for rejecting the evidence. The record is 19 comprehensive, including over two thousand pages of medical records and opinions admitted at 20 the second hearing,3 AR at 1405-3452, and over six hundred pages of medical records and 21

22 3 While the ALJ found that “medical records prepared after the end of the period under review (October 25, 2019) cannot be used to establish disability prior to that date,” Ninth Circuit law is clear that “medical 23 evaluations made after the expiration of a claimant’s insured status are relevant to an evaluation of the pre-expiration condition.” AR 1076, Taylor v. Comm’r of Soc. Sec. Admin., 659 F.3d 1228, 1232 (9th Cir. 2011) (citations omitted). 1 opinions provided at the first hearing, id. at 379-1054. The record includes notes from over fifty 2 appointments with Plaintiff’s primary care provider, Dr. Cline. Id. at 723-966, 1440-1958. It also 3 includes Plaintiff’s testimony from two hearings, and multiple function reports she completed. 4 Id. at 289-308, 318-25, 344-51, 1090-1183. The vocational expert at both hearings was asked

5 hypotheticals about the capabilities of an individual with the same physical and mental 6 limitations opined to by Dr.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
Harris v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-commissioner-of-social-security-wawd-2025.