King v. Commissioner of Social Security

CourtDistrict Court, E.D. Washington
DecidedMarch 10, 2020
Docket4:19-cv-05044
StatusUnknown

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

Bluebook
King v. Commissioner of Social Security, (E.D. Wash. 2020).

Opinion

1 Mar 10, 2020

2 SEAN F. MCAVOY, CLERK

3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 AARON K., No. 4:19-cv-05044-SMJ 5 Plaintiff, ORDER GRANTING PLAINTIFF’S 6 MOTION FOR SUMMARY v. JUDGMENT AND DENYING THE 7 COMMISSIONER’S MOTION COMMISSIONER OF SOCIAL FOR SUMMARY JUDGMENT 8 SECURITY,

9 Defendant.

11 Plaintiff Aaron K. appeals the Administrative Law Judge’s (ALJ) denial of 12 his application for Supplemental Security Income (SSI) benefits. He alleges that the 13 ALJ (1) improperly evaluated the evidence at step three of the sequential evaluation 14 process in determining that Plaintiff’s symptoms did not meet the criteria for 15 epilepsy, (2) improperly evaluated the opinions of a treating nurse practitioner, 16 (3) failed to consider the testimony of a lay witness regarding the nature and 17 frequency of Plaintiff’s seizures, (4) improperly discounted Plaintiff’s symptom 18 testimony, and (5) as a result of the preceding errors, conducted a flawed analysis 19 at steps four and five. The Commissioner of Social Security (“Commissioner”) asks 20 the Court to affirm the ALJ’s decision. 1 Before the Court, without oral argument, are the parties’ cross-motions for 2 summary judgment, ECF Nos. 11, 13. Upon reviewing the administrative record,

3 the parties’ briefs, and the relevant authority, the Court is fully informed. For the 4 reasons set forth below, the Court agrees with Plaintiff that (1) the ALJ’s analysis 5 at step three was inadequate, (2) the ALJ’s reasons for rejecting the nurse

6 practitioner’s opinions were insufficient, and (3) the ALJ’s failure to consider the 7 lay witness testimony regarding his seizures was not harmless. The Court reserves 8 ruling on Plaintiff’s claim that the ALJ failed to articulate a defensible basis for 9 rejecting Plaintiff’s symptom testimony but remands with specific direction to

10 guide the analysis. Although these errors invalidated the ALJ’s conclusion that 11 Plaintiff did not qualify for benefits, Plaintiff’s entitlement is not clear from the face 12 of the record. Accordingly, the Court grants Plaintiff’s motion for summary

13 judgment, denies the Commissioner’s motion for summary judgment, and remands 14 for further proceedings. 15 BACKGROUND1 16 Plaintiff applied for benefits on April 28, 2015. AR 160–63.2 The

17 Commissioner denied Plaintiff’s application on August 17, 2015, see AR 88–90, 18

19 1 The facts, thoroughly stated in the record and the parties’ briefs, are only briefly summarized here. 20 2 References to the administrative record (AR), ECF No. 8, are to the provided page numbers to avoid confusion. 1 and denied it again on reconsideration, see AR 96–102. At Plaintiff’s request, a 2 hearing was held before ALJ Jesse Shumway. AR 29–65. The ALJ denied Plaintiff

3 benefits on March 14, 2018. AR 10–28. The Appeals Council denied Plaintiff’s 4 request for review on January 23, 2019. AR 1–6. Plaintiff then appealed to this 5 Court under 42 U.S.C. § 405(g). ECF No. 1.

6 DISABILITY DETERMINATION 7 A “disability” is defined as the “inability to engage in any substantial gainful 8 activity by reason of any medically determinable physical or mental impairment 9 which can be expected to result in death or which has lasted or can be expected to

10 last for a continuous period of not less than twelve months.” 42 U.S.C. 11 §§ 423(d)(1)(A), 1382c(a)(3)(A). The decision-maker uses a five-step sequential 12 evaluation process to determine whether a claimant is disabled. 20 C.F.R.

13 §§ 404.1520, 416.920. 14 Step one assesses whether the claimant is engaged in substantial gainful 15 activities. If he is, benefits are denied. 20 C.F.R. §§ 404.1520(b), 416.920(b). If he 16 is not, the decision-maker proceeds to step two.

17 Step two assesses whether the claimant has a medically severe impairment or 18 combination of impairments. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant 19 does not, the disability claim is denied. If the claimant does, the evaluation proceeds

20 to the third step. 1 Step three compares the claimant’s impairment with a number of listed 2 impairments acknowledged by the Commissioner to be so severe as to preclude

3 substantial gainful activity. 20 C.F.R. §§ 404.1520(d), 404 Subpt. P App. 1, 4 416.920(d). If the impairment meets or equals one of the listed impairments, the 5 claimant is conclusively presumed to be disabled. If the impairment does not, the

6 evaluation proceeds to the fourth step. 7 Step four assesses whether the impairment prevents the claimant from 8 performing work he has performed in the past by examining the claimant’s residual 9 functional capacity, or RFC. 20 C.F.R. §§ 404.1520(e), 416.920(e). If the claimant

10 is able to perform his previous work, he is not disabled. If the claimant cannot 11 perform this work, the evaluation proceeds to the fifth step. 12 Step five, the final step, assesses whether the claimant can perform other

13 work in the national economy in view of his age, education, and work experience. 14 20 C.F.R. §§ 404.1520(f), 416.920(f); see Bowen v. Yuckert, 482 U.S. 137 (1987). 15 If the claimant can, the disability claim is denied. If the claimant cannot, the 16 disability claim is granted.

17 The burden of proof shifts during this sequential disability analysis. The 18 claimant has the initial burden of establishing a prima facie case of entitlement to 19 disability benefits. Rhinehart v. Finch, 438 F.2d 920, 921 (9th Cir. 1971). The

20 burden then shifts to the Commissioner to show (1) the claimant can perform other 1 substantial gainful activity, and (2) that a “significant number of jobs exist in the 2 national economy,” which the claimant can perform. Kail v. Heckler, 722

3 F.2d 1496, 1498 (9th Cir. 1984). A claimant is disabled only if his impairments are 4 of such severity that he is not only unable to do his previous work but cannot, 5 considering his age, education, and work experiences, engage in any other

6 substantial gainful work which exists in the national economy. 42 U.S.C. 7 §§ 423(d)(2)(A), 1382c(a)(3)(B). 8 ALJ FINDINGS 9 At step one, the ALJ found Plaintiff had not engaged in substantial gainful

10 activity. AR 15. 11 At step two, the ALJ found that Plaintiff had two medically determinable 12 severe impairments: lumbar degenerative disc disease and unspecified mixed

13 seizure disorder. Id. 14 At step three, the ALJ found that Plaintiff did not have an impairment or 15 combination of impairments that met or medically equaled the severity of a listed 16 impairment. AR 18.

17 At step four, the ALJ found that Plaintiff had an RFC sufficient to perform 18 light work as defined in 20 C.F.R. § 404

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