Lang v. Commissioner of Social Security

CourtDistrict Court, E.D. Washington
DecidedDecember 26, 2019
Docket4:18-cv-05198
StatusUnknown

This text of Lang v. Commissioner of Social Security (Lang 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
Lang v. Commissioner of Social Security, (E.D. Wash. 2019).

Opinion

1 EASTERU N. S D. I SD TI RS IT CR TI C OT F C WO AU SR HT I NGTON Dec 26, 2019 2 SEAN F. MCAVOY, CLERK 3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 SARAH L., No. 4:18-cv-05198-SMJ 5 Plaintiff, ORDER ON CROSS-MOTIONS 6 FOR SUMMARY JUDGMENT v. 7 COMMISSIONER OF SOCIAL 8 SECURITY,

9 Defendant. 10

11 Plaintiff Sarah L. appeals the Administrative Law Judge’s (ALJ) denial of 12 her application for Supplemental Security Income (SSI) benefits. She alleges that 13 the ALJ (1) improperly rejected the opinions of several medical providers, (2) 14 improperly rejected Plaintiff’s own subjective complaints, (3) failed to conduct 15 adequate analyses at steps four and five of the sequential analysis process, and (4) 16 improperly adopted the findings from a prior ALJ’s determination that Plaintiff was 17 not disabled. The Commissioner of Social Security (“Commissioner”) asks the 18 Court to affirm the ALJ’s decision. 19 Before the Court, without oral argument, are the parties’ cross-motions for 20 summary judgment, ECF Nos. 12, 13. Upon reviewing the administrative record, 1 the parties’ briefs, and the relevant authority, the Court is fully informed. For the 2 reasons set forth below, the Court agrees with Plaintiff that the ALJ improperly

3 discounted the opinions of several medical providers and that these errors were not 4 harmless. Accordingly, the Court grants Plaintiff’s motion for summary judgment, 5 denies the Commissioner’s motion for summary judgment, and remands for further

6 proceedings. 7 BACKGROUND1 8 Plaintiff applied for Supplemental Security Income on March 27, 2015. AR 9 134–142.2 The Commissioner denied Plaintiff’s application on August 24, 2015,

10 see AR 119–22, and denied it again on reconsideration, see AR 115–31. At 11 Plaintiff’s request, a hearing was held before ALJ Jesse Shumway. AR 47–77. The 12 ALJ denied Plaintiff benefits on March 13, 2018. AR 12–31. The Appeals Council

13 denied Plaintiff’s request for review on October 26, 2018. AR 1–6. Plaintiff then 14 appealed to this Court under 42 U.S.C. § 405(g). ECF No. 1. 15 DISABILITY DETERMINATION 16 A “disability” is defined as the “inability to engage in any substantial gainful

17 activity by reason of any medically determinable physical or mental impairment 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 which can be expected to result in death or which has lasted or can be expected to 2 last for a continuous period of not less than twelve months.” 42 U.S.C.

3 §§ 423(d)(1)(A), 1382c(a)(3)(A). The decision-maker uses a five-step sequential 4 evaluation process to determine whether a claimant is disabled. 20 C.F.R. 5 §§ 404.1520, 416.920.

6 Step one assesses whether the claimant is engaged in substantial gainful 7 activities. If he is, benefits are denied. 20 C.F.R. §§ 404.1520(b), 416.920(b). If he 8 is not, the decision-maker proceeds to step two. 9 Step two assesses whether the claimant has a medically severe impairment or

10 combination of impairments. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant 11 does not, the disability claim is denied. If the claimant does, the evaluation proceeds 12 to the third step.

13 Step three compares the claimant’s impairment with a number of listed 14 impairments acknowledged by the Commissioner to be so severe as to preclude 15 substantial gainful activity. 20 C.F.R. §§ 404.1520(d), 404 Subpt. P App. 1, 16 416.920(d). If the impairment meets or equals one of the listed impairments, the

17 claimant is conclusively presumed to be disabled. If the impairment does not, the 18 evaluation proceeds to the fourth step. 19 Step four assesses whether the impairment prevents the claimant from

20 performing work he has performed in the past by examining the claimant’s residual 1 functional capacity, or RFC. 20 C.F.R. §§ 404.1520(e), 416.920(e). If the claimant 2 is able to perform his previous work, he is not disabled. If the claimant cannot

3 perform this work, the evaluation proceeds to the fifth step. 4 Step five, the final step, assesses whether the claimant can perform other 5 work in the national economy in view of his age, education, and work experience.

6 20 C.F.R. §§ 404.1520(f), 416.920(f); see Bowen v. Yuckert, 482 U.S. 137 (1987). 7 If the claimant can, the disability claim is denied. If the claimant cannot, the 8 disability claim is granted. 9 The burden of proof shifts during this sequential disability analysis. The

10 claimant has the initial burden of establishing a prima facie case of entitlement to 11 disability benefits. Rhinehart v. Finch, 438 F.2d 920, 921 (9th Cir. 1971). The 12 burden then shifts to the Commissioner to show (1) the claimant can perform other

13 substantial gainful activity, and (2) that a “significant number of jobs exist in the 14 national economy,” which the claimant can perform. Kail v. Heckler, 722 F.2d 15 1496, 1498 (9th Cir. 1984). A claimant is disabled only if his impairments are of 16 such severity that he is not only unable to do his previous work but cannot,

17 considering his age, education, and work experiences, engage in any other 18 substantial gainful work which exists in the national economy. 42 U.S.C. §§ 19 423(d)(2)(A), 1382c(a)(3)(B).

20 1 ALJ FINDINGS 2 At step one, the ALJ found Plaintiff had not engaged in substantial gainful

3 activity. AR 17. 4 At step two, the ALJ found that Plaintiff had four medically determinable 5 severe impairments: fibromyalgia, bipolar disorder, personality disorder, and

6 substance addiction disorder. Id. The ALJ did not find that Plaintiff’s asthma, 7 obesity, chronic fatigue syndrome, somatic symptom disorder, obsessive- 8 compulsive disorder, or attention deficit hyperactive disorder were severe 9 impairments. AR 17–18. The ALJ adopted this finding from another ALJ’s finding,

10 in Plaintiff’s 2010 appeal from a denial of benefits, because he found “insufficient 11 new and material evidence to warrant a departure from that finding.” Id. 12 At step three, the ALJ found that Plaintiff did not have an impairment or

13 combination of impairments that met or medically equaled the severity of a listed 14 impairment. AR 18. 15 At step four, the ALJ found that Plaintiff had an RFC sufficient to perform 16 light work as defined in 20 C.F.R. § 419.967(b) with the following limitations:

17 “[she] is able to perform work where interpersonal contact is incidental to work 18 performed; complexity of tasks is learned and performed by rote, few variables, and 19 little judgment; and supervision required is simple, direct, and concrete (unskilled).”

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

Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Shinseki, Secretary of Veterans Affairs v. Sanders
556 U.S. 396 (Supreme Court, 2009)
Parker v. City of Nashua
76 F.3d 9 (First Circuit, 1996)
Muhammad Chaudhry v. Michael Astrue
688 F.3d 661 (Ninth Circuit, 2012)
Hoopai v. Astrue
499 F.3d 1071 (Ninth Circuit, 2007)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Adrian Burrell v. Carolyn W. Colvin
775 F.3d 1133 (Ninth Circuit, 2014)
Kelley v. Environmental Protection Agency
15 F.3d 1100 (D.C. Circuit, 1994)
Smolen v. Chater
80 F.3d 1273 (Ninth Circuit, 1996)
Lester v. Chater
81 F.3d 821 (Ninth Circuit, 1995)
Cohen v. General Motors Corp.
533 F.3d 1 (First Circuit, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Lang v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lang-v-commissioner-of-social-security-waed-2019.