Ingram v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedSeptember 27, 2024
Docket3:24-cv-05125
StatusUnknown

This text of Ingram v. Commissioner of Social Security (Ingram 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
Ingram v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 SANDRA I., 9 Plaintiff, Case No. C24-5125-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of her application for Supplemental Security Income 15 and Disability Insurance Benefits.1 Plaintiff contends the administrative law judge (“ALJ”) erred 16 by misevaluating the medical evidence, her testimony, and lay witness statements, resulting in an 17 erroneous residual functional capacity (“RFC”) assessment. (Dkt. # 16.) As discussed below, the 18 Court AFFIRMS the Commissioner’s final decision and DISMISSES the case with prejudice. 19 20 21 22 23

1 The parties consented to proceed before the undersigned Magistrate Judge. (Dkt. # 5.) 1 II. BACKGROUND 2 Plaintiff was born in 1988, has a high school education, and has past relevant work as a 3 cashier, home attendant, nurse assistant, and hostess. AR at 967. Plaintiff has not engaged in 4 substantial gainful activity since her alleged onset date. Id. at 955.

5 In November 2018 and August 2019, Plaintiff applied for benefits, alleging disability as 6 of June 2017. AR at 952. Plaintiff’s applications were denied initially and on reconsideration, 7 and Plaintiff requested a hearing. Id. After the ALJ conducted hearings in October 2020 and 8 February 2021, the ALJ issued a decision finding Plaintiff not disabled. Id. at 16-38. The 9 Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the 10 Commissioner’s final decision. Id. at 1-6. Plaintiff appealed the final decision of the 11 Commissioner to this Court. On remand, based on the parties’ stipulation, this Court reversed the 12 ALJ’s decision and remanded the case for further proceedings. AR at 1037-39. After the ALJ 13 conducted a hearing in August 2023, the ALJ again issued a decision finding Plaintiff not 14 disabled. Id. at 949-77.

15 Using the five-step disability evaluation process,2 the ALJ found, in pertinent part, 16 Plaintiff has the severe impairments of depressive disorder, bipolar disorder, anxiety disorder, 17 and posttraumatic stress disorder. AR at 956. The ALJ also determined that Plaintiff could 18 perform a full range of work at all exertional levels but with the following nonexertional 19 limitations: she can perform simple repetitive tasks; she can work superficially and occasionally 20 with the general public; she can work in the same room as coworkers but not in coordination 21 with them; she can interact occasionally with supervisors; and she can adapt to simple, 22 occasional workplace changes. Id. at 960. Plaintiff’s appeal followed. (Dkt. # 8.) 23

2 20 C.F.R. §§ 404.1520, 416.920. 1 III. LEGAL STANDARDS 2 Under 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of social 3 security benefits when the ALJ’s findings are based on legal error or not supported by substantial 4 evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 (9th Cir. 2005). As a

5 general principle, an ALJ’s error may be deemed harmless where it is “inconsequential to the 6 ultimate nondisability determination.” Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012) 7 (cited sources omitted). The Court looks to “the record as a whole to determine whether the error 8 alters the outcome of the case.” Id. 9 “Substantial evidence” is more than a scintilla, less than a preponderance, and is such 10 relevant evidence as a reasonable mind might accept as adequate to support a conclusion. 11 Richardson v. Perales, 402 U.S. 389, 401 (1971); Magallanes v. Bowen, 881 F.2d 747, 750 (9th 12 Cir. 1989). The ALJ is responsible for determining credibility, resolving conflicts in medical 13 testimony, and resolving any other ambiguities that might exist. Andrews v. Shalala, 53 F.3d 14 1035, 1039 (9th Cir. 1995). While the Court is required to examine the record as a whole, it may

15 neither reweigh the evidence nor substitute its judgment for that of the Commissioner. Thomas v. 16 Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When the evidence is susceptible to more than one 17 rational interpretation, it is the Commissioner’s conclusion that must be upheld. Id. 18 IV. DISCUSSION 19 A. The ALJ Did Not Err in Evaluating Medical Evidence 20 Under regulations applicable to this case, the ALJ is required to articulate the 21 persuasiveness of each medical opinion, specifically whether the opinions are supported and 22 consistent with the record. 20 C.F.R. §§ 404.1520c(a)-(c), 416.920c(a)-(c). These findings must 23 be supported by substantial evidence. Woods v. Kijakazi, 32 F.4th 785, 792 (9th Cir. 2022). 1 1. Kellya Campbell, ARNP 2 In August 2020, ARNP Campbell—citing interviews and diagnoses—opined that 3 Plaintiff’s emotional instability, lack of trust, and difficulty mobilizing resources prevented her 4 from working more than ten hours per week. AR at 589-91. The ALJ rejected this opinion,

5 finding it unpersuasive due to its conclusory nature, the absence of evidence indicating that 6 Plaintiff’s daily activities had been reviewed, and because it was a checkbox form completed for 7 a different program. Id. at 966. The ALJ also questioned ARNP Campbell’s treating relationship 8 with Plaintiff. Id. 9 Plaintiff asserts that the ALJ overlooked ARNP Campbell’s longstanding treatment 10 relationship and that her opinion was consistent with her clinical observations. (Dkt. # 16 at 5-6.) 11 The Commissioner acknowledges that the ALJ erred in discounting ARNP Campbell’s role as 12 Plaintiff’s psychiatric nurse, but contends this error was harmless. (Dkt. # 18 at 12.) The 13 Commissioner argues that the ALJ properly considered ARNP Campbell’s opinion in light of its 14 supportability and consistency, and adequately discussed her clinical observations when

15 evaluating Plaintiff’s testimony. (Id.) The Court agrees. 16 The ALJ cited ample evidence contradicting ARNP Campbell’s assessment of severely 17 limiting mental health symptoms. AR at 962, 965-66. An ALJ may weigh the quality of a 18 medical opinion’s explanation and reject it when contradicted by objective evidence in the 19 medical record. See Ford v. Saul, 950 F.3d 1141, 1156 (9th Cir. 2020). Records consistently 20 demonstrated that Plaintiff was cooperative, engaged, and appropriate; had a normal mood and 21 affect and was not in acute distress; was fully alert and oriented, with logical, goal-directed 22 thoughts, normal and fluent speech, and no signs of psychosis, hallucinations, delusions, or 23 suicidal ideation; exhibited normal insight, judgment, memory, attention, and concentration; 1 improved with treatment; and engaged in various activities such as driving, caring for her three 2 children, and attending college classes. AR at 962, 965-66.3 The ALJ reasonably concluded that 3 this evidence was inconsistent with ARNP Campbell’s vague opinion that Plaintiff’s mental 4 symptoms precluded her from working more than ten hours per week. Id. at 966.

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Ingram v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ingram-v-commissioner-of-social-security-wawd-2024.