Latham v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJuly 11, 2024
Docket2:24-cv-00092
StatusUnknown

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

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 CHRISTINA M L., 8 Plaintiff, Case No. C24-0092 RSM 9 v. ORDER REVERSING DENIAL OF 10 BENEFITS AND REMANDING COMMISSIONER OF SOCIAL SECURITY, FOR FURTHER PROCEEDINGS 11 Defendant. 12

13 Plaintiff seeks review of the denial of her applications for Supplemental Security Income 14 (SSI) and Disability Insurance Benefits (DIB). Plaintiff contends the ALJ erred at step two, 15 improperly evaluated her symptom testimony, and improperly rejected lay witness testimony. 16 Dkt. 8. As discussed below, the Court REVERSES the Commissioner’s final decision and 17 REMANDS the matter for further administrative proceedings under sentence four of 42 U.S.C. § 18 405(g). 19 BACKGROUND 20 Plaintiff is 47 years old, has at least a high school education, and has worked as a cashier, 21 home attendant, baker, material handler, child care attendant/nursery, and apartment house 22 manager. Admin. Record (AR) 33. In November 2020, Plaintiff applied for benefits, alleging 23 disability as of January 1, 2017. AR 78, 90, 104, 115. Plaintiff’s applications were denied ORDER REVERSING DENIAL OF 1 initially and on reconsideration. AR 89, 101, 113, 124. The ALJ conducted a hearing on 2 October 6, 2022, where Plaintiff amended her alleged onset date to June 30, 2019 (AR 42–75.) 3 and issued a decision on January 17, 2023, finding Plaintiff not disabled. AR 15–41. 4 DISCUSSION 5 The Court may reverse the ALJ’s decision only if it is legally erroneous or not supported 6 by substantial evidence of record. Ford v. Saul, 950 F.3d 1141, 1154 (9th Cir. 2020). The Court 7 must examine the record but cannot reweigh the evidence or substitute its judgment for the 8 ALJ’s. Thomas v. Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When evidence is susceptible to 9 more than one interpretation, the Court must uphold the ALJ’s interpretation if rational. Ford, 10 950 F.3d at 1154. Also, the Court “may not reverse an ALJ’s decision on account of an error

11 that is harmless.” Molina v. Astrue, 674 F.3d 1104, 1111 (9th Cir. 2012). 12 1. Step Two 13 Plaintiff contends the ALJ erred by finding her gastrointestinal issues not severe at step 14 two. Dkt. 8 at 3–6. 15 At step two, the ALJ must determine if the claimant has a medically determinable 16 impairment or combination of impairments that are severe, such that they would significantly 17 limit the claimant’s ability to perform basic work activities. See Smolen v. Chater, 80 F.3d 1273, 18 1289–90 (9th Cir. 1996) (citation omitted); 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). 19 “Basic work activities are ‘abilities and aptitudes necessary to do most jobs.’” Smolen, 80 F.3d 20 at 1290. The claimant retains the burden of proof at step two. See Parra v. Astrue, 481 F.3d

21 742, 746 (9th Cir. 2007). The step-two inquiry is “merely a threshold determination meant to 22 screen out weak claims.” Buck v. Berryhill, 869 F.3d 1040, 1048 (9th Cir. 2017) (citing Bowen 23 v. Yuckert, 482 U.S. 137, 146–47 (1987)). As long as the claimant has at least one severe ORDER REVERSING DENIAL OF 1 impairment, the disability inquiry moves on to step three. See 20 C.F.R. §§ 404.1520(d), 2 416.920(d). The step-two inquiry “is not meant to identify the impairments that should be taken 3 into account when determining the RFC.” Buck, 869 F.3d at 1048–49. 4 Here, the ALJ reasonably found Plaintiff’s gastrointestinal issues not severe. The ALJ 5 pointed to Plaintiff’s normal abdomen scan, colon biopsies, colonoscopy and unremarkable 6 EGD. AR 1215, 3495, 3501–02, 3509, 3523, 3591–93. The ALJ also noted Plaintiff’s bowel 7 movements were not as frequent as alleged, given Plaintiff’s lack of reports of such issues or 8 explicit denial of diarrhea or frequent urination throughout the record. AR 1837, 1847. While 9 there were records noting Plaintiff’s chronic diarrhea, the ALJ also highlighted Plaintiff’s reports 10 of improvements after following a special diet or taking medication. AR 3058, 3521. Plaintiff

11 points out she still presented symptoms even with medication and was diagnosed with chronic 12 diarrhea, Dkt. 8 at 5, but she has not sufficiently shown her cited evidence would necessarily 13 significantly limit her ability to perform basic work activities. 14 Further, even if the ALJ had erred in finding Plaintiff’s gastrointestinal issues not severe, 15 “a claimant cannot be prejudiced by failure to consider a particular impairment severe at step two 16 as long as the ALJ finds the claimant has at least one severe impairment, and still addresses the 17 non-severe impairment when considering the claimant’s [residual functional capacity].” See 18 Buck, 869 F.3d at 1049. (citing Molina, 674 F.3d at 1115). Here, after finding Plaintiff’s 19 gastrointestinal issues not severe, the ALJ proceeded to consider them in assessing her RFC. See 20 AR 31–33. Whether the ALJ properly did so is further discussed below.

21 2. Plaintiff’s Symptom Testimony 22 Plaintiff contends the ALJ erred in rejecting her testimony regarding her back pain, 23 mental health symptoms, and gastrointestinal issues. Dkt. 8 at 6–17. ORDER REVERSING DENIAL OF 1 Plaintiff testified her gastrointestinal issues cause sudden bladder and bowel movements. 2 AR 52. She stated she often has to go to the bathroom one to four times a day on average, 3 though she does have fluctuations every two weeks where she has to use to bathroom seven to 4 ten times a day. Id. Plaintiff also testified to back pain after enduring a fall. AR 54. She 5 explained that because of her back pain, she moves at slow pace and has to lie down at times 6 during her caretaking job. AR 57–58. She explained that on a regular eight-hour workday, she 7 has to lie down for a total of an hour and a half to three or more hours. AR 59. Plaintiff further 8 testified to having brain fog and difficulties with thinking clearly and concentrating. AR 56. 9 Where, as here, an ALJ determines a claimant has presented objective medical evidence 10 establishing underlying impairments that could cause the symptoms alleged, and there is no

11 affirmative evidence of malingering, the ALJ can only discount the claimant’s testimony as to 12 symptom severity by providing “specific, clear, and convincing” reasons supported by 13 substantial evidence. Trevizo v. Berryhill, 871 F.3d 664, 678 (9th Cir. 2017). “The standard 14 isn’t whether our court is convinced, but instead whether the ALJ’s rationale is clear enough that 15 it has the power to convince.” Smartt v. Kijakazi, 53 F.4th 489, 499 (9th Cir. 2022). 16 a. Back Pain 17 In rejecting Plaintiff’s testimony regarding her back pain, the ALJ first pointed to the 18 “modest examination findings” throughout Plaintiff’s record. AR 27–28. “When objective 19 medical evidence in the record is inconsistent with the claimant’s subjective testimony, the ALJ 20 may indeed weigh it as undercutting such testimony.” Smartt, 53 F.4th at 498. The ALJ’s

21 assessment is reasonable.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Lingenfelter v. Astrue
504 F.3d 1028 (Ninth Circuit, 2007)
April Dominguez v. Carolyn Colvin
808 F.3d 403 (Ninth Circuit, 2015)
Gavin Buck v. Nancy Berryhill
869 F.3d 1040 (Ninth Circuit, 2017)
Leopoldo Leon v. Nancy Berryhill
880 F.3d 1041 (Ninth Circuit, 2017)
Michelle Ford v. Andrew Saul
950 F.3d 1141 (Ninth Circuit, 2020)
Johnson v. Shalala
60 F.3d 1428 (Ninth Circuit, 1995)
Smolen v. Chater
80 F.3d 1273 (Ninth Circuit, 1996)
Denmark v. Liberty Life Assurance Co.
481 F.3d 16 (First Circuit, 2007)
Trevizo v. Berryhill
871 F.3d 664 (Ninth Circuit, 2017)

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Bluebook (online)
Latham v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/latham-v-commissioner-of-social-security-wawd-2024.