Lamere v. Dudek

CourtDistrict Court, E.D. Washington
DecidedApril 28, 2025
Docket2:24-cv-00376
StatusUnknown

This text of Lamere v. Dudek (Lamere v. Dudek) 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
Lamere v. Dudek, (E.D. Wash. 2025).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Apr 28, 2025

SEAN F. MCAVOY, CLERK 3 UNITED STATES DISTRICT COURT 4 EASTERN DISTRICT OF WASHINGTON

5 MARCUS L.,1 No. 4:24-cv-376-EFS 6 Plaintiff, 7 ORDER REVERSING THE v. ALJ’S DENIAL OF BENEFITS, 8 AND REMANDING FOR LELAND DUDEK, Acting MORE PROCEEDINGS 9 Commissioner of Social Security,2

10 Defendant.

11 Plaintiff Marcus L. asks the Court to reverse the Administrative 12 Law Judge’s (ALJ) denial of Title 2 and Title 16 benefits. Because the 13 14

15 1 For privacy reasons, Plaintiff is referred to by first name and last 16 initial or as “Plaintiff.” See LCivR 5.2(c). 17 2 Leland Dudek has been named the Acting Commissioner of Social 18 Security. Pursuant to Federal Rule of Civil Procedure 25(d) and 42 19 U.S.C. § 405(g), he is hereby substituted as the Defendant. 20 1 ALJ failed to fairly and fully consider the treatment records and

2 mental-health medical opinions, the ALJ erred. This matter is 3 remanded for further proceedings. 4 I. Background

5 On February 22, 2021, Plaintiff applied for benefits, at the age of 6 28, claiming disability under Titles 2 and 16, beginning February 1, 7 2020, based on physical and mental impairments.3 The agency denied

8 Plaintiff’s applications for benefits; thereafter, ALJ Joyce Frost-Wolf 9 held a telephonic hearing in September 2023, at which Plaintiff and a 10 vocational expert testified.4

11 Plaintiff, who has a GED, testified about his most recent jobs, 12 including working at a cabinetry company for one of his brothers doing 13 tasks such as putting on hinges.5 Plaintiff testified that, even though

14 his brother was his supervisor and was patient with his mistakes, he 15 16

17 3 AR 228–52. 18 4 AR 51–84, 131–38. 19 5 AR 59–61. 20 1 ultimately had to stop working due to his poor performance.6 He also

2 worked for his brother-in-law in the construction industry, helping 3 retrieve tools or ladders; he did not do any cutting or measuring 4 because he has difficulty following instructions.7 Again, he lost that

5 employment due to poor performance. 6 Plaintiff testified that he last used methamphetamine and 7 heroine in 2021.8 Plaintiff said that his post-traumatic stress disorder

8 (PTSD) is triggered sometimes when watching television or by a loud 9 noise and that being around too many people triggers his anxiety and 10 panic attacks.9 To feel secure, he rarely leaves the house, and his

11 paranoia causes him to see things several times a week.10 Plaintiff 12 stated that his driver’s license is suspended, and if he goes shopping, 13

15 6 AR 61, 72. 16 7 AR 70. 17 8 AR 64. 18 9 AR 68–69. 19 10 AR 63, 69. 20 1 he has a caregiver go with him.11 He said he can help with dishes and

2 other light house chores if his paranoia, panic attacks, and legs are not 3 bothering him.12 He shared that he plays computer games and watches 4 TV.13

5 After the hearing, the ALJ issued a decision denying benefits.14 6 The ALJ found Plaintiff’s alleged symptoms were not entirely 7

8 9 10

11 11 AR 62. 12 12 AR 62. 13 13 AR 62. 14 14 AR 19–50. Per 20 C.F.R. §§ 404.1520(a)–(g), 416.920(a)–(g), a five- 15 step evaluation determines whether a claimant is disabled. If there is 16 medical evidence of drug or alcohol addiction, the ALJ must then 17 determine whether drug or alcohol use is a material factor contributing 18 to the disability. 42 U.S.C. § 423(d)(2)(C); 20 C.F.R. § 416.935; Sousa v. 19 Callahan, 143 F.3d 1240, 1245 (9th Cir. 1998). 20 1 consistent with the medical evidence and other evidence.15 The ALJ

2 considered the lay statement from Plaintiff’s mother.16 As to the 3 mental-health opinions,17 the ALJ found: 4 • the prior administrative findings of Vincent Gollogly, PhD, and

5 Renee Eisenhauer18 partially persuasive. 6 • the evaluating opinions of Thomas Genthe, PhD, not 7 persuasive.19

8 As to the sequential disability analysis, the ALJ found: 9

10 15 AR 34–37. As recommended by the Ninth Circuit in Smartt v. 11 Kijakazi, the ALJ should consider replacing the phrase “not entirely 12 consistent” with “inconsistent.” 53 F.4th 489, 499, n.2 (9th Cir. 2022). 13 16 AR 33, 318. 14 17 Because Plaintiff’s appeal focuses solely on his mental-health 15 impairments, the Court discusses only the mental-health opinions. 16 18 The record does not identify Renee Eisenhauer’s degree but lists her 17 name after “MC/PC Signature” and identifies “Medical Specialty Code: 18 38 Psychology.” AR 111. 19 19 AR 38–41. 20 1 • Plaintiff met the insured status requirements through June

2 30, 2023. 3 • Step one: Plaintiff had not engaged in substantial gainful 4 activity since February 1, 2020, the alleged onset date.

5 • Step two: Plaintiff had the following medically determinable 6 severe impairments: lumbar degenerative disc disease; 7 depressive disorder; anxiety disorder; cardiomyopathy, status

8 post valve repair; polysubstance use; schizophrenia; PTSD; 9 attention deficit hyperactivity disorder (ADHD); and right leg 10 status-post surgeries for necrotizing issues.

11 • Step three: Plaintiff did not have an impairment or 12 combination of impairments that met or medically equaled the 13 severity of one of the listed impairments.

14 • RFC: Plaintiff had the RFC to perform light work except: 15 the claimant can occasionally use ramps or stairs; cannot use ladders, ropes, or scaffolds; can 16 occasionally perform balancing, stooping, kneeling, crouching, or crawling; occasional work around heavy 17 machinery with fast moving parts or at unprotected heights; can understand and remember simple tasks; 18 can maintain attention, concentration, and pace for simple tasks in two hour periods; can have occasional 19 public contact without tasks that require public interaction (examples of tasks requiring public 20 1 interaction are jobs with tasks that require a transaction with the public, monitoring or supervising 2 the public, or answering public questions); can have occasional co-worker and supervisor contact other 3 than periods of instruction (periods of instruction being the initial training and explanation of changes 4 to work tasks or routine); can make simple work- related decisions; and can tolerate occasional changes 5 to job tasks with explanation provided.

6 • Step four: Plaintiff cannot perform past relevant work. 7 • Step five: considering Plaintiff’s RFC, age, education, and work 8 history, Plaintiff could perform work that existed in significant 9 numbers in the national economy, such as electrode cleaner, 10 garment folder, and bakery inspector.20 11 Plaintiff timely requested review of the ALJ’s decision by the 12 Appeals Council and now this Court.21 13 II. Standard of Review 14 The ALJ’s decision is reversed “only if it is not supported by 15 substantial evidence or is based on legal error” and such error 16

18 20 AR 22–44. 19 21 AR 1–6. 20 1 impacted the nondisability determination.22 Substantial evidence is

2 “more than a mere scintilla but less than a preponderance; it is such 3 relevant evidence as a reasonable mind might accept as adequate to 4 support a conclusion.”23

5 III. Analysis 6 Plaintiff argues the ALJ improperly evaluated the medical 7

8 22 Hill v.

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Lamere v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lamere-v-dudek-waed-2025.