Jaime S. Dawson v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedOctober 1, 2025
Docket2:24-cv-02407
StatusUnknown

This text of Jaime S. Dawson v. Commissioner of Social Security (Jaime S. Dawson v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jaime S. Dawson v. Commissioner of Social Security, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JAIME S. DAWSON, No. 2:24-cv-02407-DAD-DMC 12 Plaintiff, 13 v. ORDER ADOPTING FINDINGS AND RECOMMENDATIONS, DENYING 14 COMMISSIONER OF SOCIAL PLAINTIFF’S MOTION FOR SUMMARY SECURITY, JUDGMENT, AND GRANTING 15 DEFENDANT’S CROSS-MOTION FOR Defendant. SUMMARY JUDGMENT 16 (Doc. Nos. 13, 15, 16, 20) 17

18 19 Plaintiff Jaime S. Dawson, proceeding with counsel, brought this action seeking judicial 20 review of the Commissioner of Social Security’s final decision denying her application for 21 disability insurance benefits and supplemental security income under the Social Security Act. 22 (Doc. No. 1.) The matter was referred to a United States Magistrate Judge pursuant to 28 U.S.C. 23 § 636(b)(1)(B) and Local Rule 302. 24 On August 25, 2025, the assigned magistrate judge issued findings and recommendations 25 recommending that plaintiff’s motion for summary judgment in her favor (Doc. No. 13) be 26 denied, that the defendant Commissioner’s cross-motion for summary judgment (Doc. Nos. 15, 27 16) be granted, and that defendant’s decision denying plaintiff’s application for benefits be 28 affirmed. (Doc. No. 20 at 22.) Specifically, the magistrate judge concluded that the 1 administrative law judge (“ALJ”) did not err at Step 2 in finding that plaintiff’s impairments of 2 anxiety and panic disorder are non-severe, that the ALJ’s discounting of Dr. Washington’s 3 medical opinion was supported by substantial evidence, and that the ALJ had supported the 4 finding that plaintiff’s subjective testimony conflicted with objective medical evidence with 5 sufficient specificity. (Id. at 5–20.) Accordingly, the magistrate judge concluded that the ALJ 6 did not err in finding that plaintiff was not disabled prior to November 24, 2023. (Id. at 22.) 7 Those findings and recommendations were served on the parties and contained notice that 8 any objections thereto were to be filed within fourteen (14) days after service. (Id.) Plaintiff 9 timely filed her objections on September 8, 2025. (Doc. No. 21.) The defendant Commissioner 10 filed a response thereto on September 9, 2025. (Doc. No. 22.) 11 In her objections, plaintiff argued that the ALJ’s rationale for finding her mental 12 impairments to be “non-severe” relied on non-objective evidence, that the ALJ improperly 13 rejected aspects of Dr. Washington’s medical opinions on the basis of non-objective evidence, 14 that the ALJ improperly discounted plaintiff’s subjective testimony by failing to provide specific, 15 clear and convincing reasons, and that the ALJ improperly discounted the lay opinion testimony 16 of plaintiff’s fiancé. (Doc. No. 21 at 5–13.) The court will consider each of these arguments in 17 turn. 18 First, plaintiff contends that the ALJ erred in reaching the conclusion at Step Two of the 19 sequential evaluation analysis that plaintiff’s anxiety and panic disorder were non-severe 20 impairments. (Doc. No. 21 at 5–8.) “If the ALJ erroneously determines that an alleged 21 impairment is not ‘severe’ at Step Two, a reviewing court must assess whether the error was 22 harmless.” Williams v. Colvin, 24 F. Supp. 3d 901, 917 (N.D. Cal. 2014) (citing Lewis v. Astrue, 23 498 F.3d 909, 911 (9th Cir. 2007)). A failure to consider a mental impairment as severe at Step 24 Two is harmless when the ALJ discusses that impairment during the ALJ’s residual functional 25 capacity assessment at Step 4. Lee v. Astrue, 472 F. App’x 553, 555 (9th Cir. 2012)1. Here, the 26 ALJ did discuss plaintiff’s anxiety and panic disorders in the context of the residual functional 27 1 Citation to the unpublished Ninth Circuit opinions cited throughout this order is appropriate 28 pursuant to Ninth Circuit Rule 36-3(b). 1 capacity analysis. (Doc. No. 10-3 at 25.) Accordingly, even if the ALJ erred in finding that 2 plaintiff’s anxiety and panic disorders were not severe, such error was harmless because the ALJ 3 still discussed those symptoms at Step 4 of the analysis. See Mina v. Berryhill, No. 2:17-cv- 4 01381-DB, 2018 WL 4215627, at *4 (E.D. Cal. Sept. 5, 2018) (concluding that any error 5 committed by the ALJ in finding that the plaintiff’s depressive disorder was not severe was 6 harmless because it was considered at the Step Four residual functional capacity analysis); see 7 also Williams, 24 F. Supp. 3d at 917–18 (holding the same in the context of anxiety and panic 8 disorder impairments). The court therefore rejects plaintiff’s first argument as unpersuasive. 9 Second, plaintiff argues that the ALJ erred by rejecting Dr. Washington’s medical 10 opinions because the reasons for doing so were cursory in nature. (Doc. No. 21 at 8–9.) 11 “Plaintiff’s claim for benefits is governed by the agency’s ‘new’ regulations concerning how 12 ALJs must evaluate medical opinions for claims filed on or after March 27, 2017.” Callahan v. 13 Kijakazi, 657 F. Supp. 3d 1368, 1380 (E.D. Cal. 2023) (citing 20 C.F.R. § 404.1520c). The Ninth 14 Circuit has clarified what an ALJ must consider when evaluating a medical opinion: 15 The revised social security regulations are clearly irreconcilable with our caselaw according special deference to the opinions of treating 16 and examining physicians on account of their relationship with the claimant. Our requirement that ALJs provide “specific and 17 legitimate reasons” for rejecting a treating or examining doctor’s opinion, which stems from the special weight given to such opinions, 18 is likewise incompatible with the revised regulations. . . . Even under the new regulations, an ALJ cannot reject an examining or 19 treating doctor’s opinion as unsupported or inconsistent without providing an explanation supported by substantial evidence. The 20 agency must “articulate . . . how persuasive” it finds “all of the medical opinions” from each doctor or other source and “explain 21 how [it] considered the supportability and consistency factors” in reaching those findings. 22 23 Woods v. Kijakazi, 32 F.4th 785, 792 (9th Cir. 2022) (internal citations omitted). The 24 supportability factor pertains to “the extent to which a medical source supports the medical 25 opinion by explaining the relevant objective medical evidence.” Id. at 791–92 (internal quotation 26 marks and ellipses omitted). The consistency factor pertains to “the extent to which a medical 27 opinion is consistent with the evidence from other medical sources and nonmedical sources in the 28 claim.” Id. at 792 (internal quotation marks and ellipses omitted). Though the ALJ must consider 1 these two factors, they are “not required to incant the magic words of supportability and 2 consistency in [their] findings.” Darling v. Kijakazi, No. 22-35594, 2023 WL 4103935, at *2 3 (9th Cir. June 21, 2023) (internal quotation marks omitted); see also Baker v. O’Malley, No. 1:24- 4 cv-00277-SKO, 2024 WL 4534578, at *9 n.5 (E.D. Cal. Oct. 21, 2024) (finding that an ALJ 5 properly evaluated medical evidence where there was substantial evidence supporting evaluation 6 of supportability and consistency regardless of whether the ALJ used those terms). 7 As to supportability, plaintiff contends that the ALJ erred by finding that her mental status 8 examinations, which indicated only mild impairments in “broad functional areas of mental 9 functioning,” were inconsistent with Dr. Washington’s medical opinion that she had “moderate 10 impairment in her ability to complete a normal workday or workweek. (Doc. Nos.

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Bluebook (online)
Jaime S. Dawson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jaime-s-dawson-v-commissioner-of-social-security-caed-2025.