Lawton v. Dudek

CourtDistrict Court, E.D. Washington
DecidedApril 9, 2025
Docket2:24-cv-00343
StatusUnknown

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

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Apr 09, 2025

3 SEAN F. MCAVOY, CLERK 4 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 5

6 DUANE L.,1 No. 4:24-cv-343-EFS

7 Plaintiff, ORDER REVERSING THE ALJ’S 8 v. DENIAL OF BENEFITS, AND REMANDING FOR MORE 9 LELAND DUDEK, Acting PROCEEDINGS Commissioner of Social Security,2 10 Defendant. 11 12 13 Plaintiff Duane L. asks the Court to reverse the Administrative Law Judge’s 14 (ALJ) denial of Title 2 and Title 16 benefits. One of Plaintiff’s arguments is that 15 the ALJ erred by not finding intermittent explosive disorder to be a severe 16 impairment. The Court agrees the ALJ erred at step two. Because this error 17

18 1 For privacy reasons, Plaintiff is referred to by first name and last initial or as 19 “Plaintiff.” See LCivR 5.2(c). 20 2 Leland Dudek has been named the Acting Commissioner of Social Security. 21 Pursuant to Federal Rule of Civil Procedure 25(d) and 42 U.S.C. § 405(g), he is 22 hereby substituted as the Defendant. 23 1 impacted the ALJ’s disability evaluation, remand for further proceedings is 2 required.

3 I. Background 4 Plaintiff applied for Title 2 and Title 16 benefits, claiming disability 5 beginning April 1, 2012, based on mental-health and intellectual impairments.3 6 After the agency denied benefits, ALJ Marie Palachuk held a telephone hearing in 7 October 2023, at which Plaintiff and a vocational expert testified.4 Plaintiff 8 testified that he completed either 7th or 8th grade and that he had been in special 9 education for most of his schooling.5 Later he attempted to obtain his GED but he

10 was unable to pass the tests due to difficulties reading and concentrating.6 He said 11 that he was able to pass the knowledge portion of his driver’s examination on the 12 third try after studying extensively at home.7 He testified that he probably lost 13 prior jobs due to his attitude, as he gets angry when someone exercises their 14 “authority a little too far and push[es his] buttons.”8 He has worked several jobs in 15

17 3 AR 170–71. 18 4 AR 35–69. 19 5 AR 40. 20 6 AR 40. 21 7 AR 41. 22 8 AR 48. 23 1 the past but they are typically only one-day or up to one year.9 He testified that he 2 volunteered at a local food bank for about two days a week; he “would go down and

3 give them a hand, like going and getting food from Safeway, and bringing it back to 4 their place, and dropping it off. And then that was pretty much it.”10 Sometimes he 5 would help pass out food or bag up food when the food bank handed out food every 6 other weekend.11 He stopped volunteering at the food bank when his friend who 7 worked there died.12 He testified that he smokes marijuana every day because “it 8 kind of winds me down sometimes.”13 He stated he is unable to “keep my head on 9 one thing at a time,” as “it’s bouncing all over the place,” and he has borderline

10 intelligence.14 During a typical day, he does a variety of things, such as helping 11 others with house projects or spending time in nature, as he tries not to stay in the 12 house or else he and his wife will end up arguing.15 Plaintiff also testified that he 13 has been having problems with feeling in his fingers and toes.16 14

15 9 AR 48–50. 16 10 AR 51. 17 11 AR 51. 18 12 AR 51. 19 13 AR 52. 20 14 AR 53. 21 15 AR 54–55. 22 16 AR 60. 23 1 After the hearing, the ALJ issued a decision denying benefits.17 The ALJ 2 found Plaintiff’s alleged symptoms were “not entirely consistent with” the medical

3 evidence and other evidence.18 The ALJ considered the lay statement from 4 Plaintiff’s wife.19 The ALJ found each of the medical opinions and prior 5 administrative findings unpersuasive: 6 • The psychological evaluations of Donald Bonner, EdD, Douglas Brady, 7 PhD, and Thomas Horner, PhD, were unpersuasive because they were 8 “too attenuated in time and not illustrative of the claimant’s 9 functioning during the period at issue.”20

10 11

12 17 AR 14–34. Per 20 C.F.R. §§ 404.1520(a)–(g), 416.920(a)–(g), a five-step 13 evaluation determines whether a claimant is disabled. 14 18 AR 23. As recommended by the Ninth Circuit in Smartt v. Kijakazi, the ALJ 15 should consider replacing the phrase “not entirely consistent” with “inconsistent.” 16 53 F.4th 489, 499, n.2 (9th Cir. 2022). 17 19 AR 27. 18 20 AR 26. For this same reason, the ALJ found unpersuasive a letter from a 19 Learning Disability Specialist in 1982 that generally described that Plaintiff’s 20 ability to attend to and complete tasks, retain information, and manage his 21 attitude and behavior had improved with medication. AR 26 (citing AR 282, 302, 22 1187). 23 1 • The prior administrative findings of W. Miller Logan, PhD, and 2 Michael Brown that the record was insufficient to substantiate the

3 presence of a severe impairment were unpersuasive because the 4 treatment records established severe mental impairments and 5 limiting effects.21 6 As to the sequential disability analysis, the ALJ found: 7 • Plaintiff met the insured status requirements through December 31, 8 2013. 9 • Step one: Plaintiff had not engaged in substantial gainful activity

10 since April 1, 2012, the alleged onset date. 11 • Step two: Plaintiff had the following medically determinable severe 12 impairments: learning disorder/borderline intellectual functioning, 13 attention-deficit/hyperactivity disorder (ADHD), and polysubstance 14 abuse disorder. 15 • Step three: Plaintiff did not have an impairment or combination of

16 impairments that met or medically equaled the severity of one of the 17 listed impairments. 18 • RFC: Plaintiff had the RFC to perform a full range of work at all 19 exertional levels with the following nonexertional limitations: 20

21 21 AR 26–27. The record does not reflect what Michael Brown’s medical degree was, 22 simply stating, “Medical Specialty Code: 38 Psychology.” AR 86. 23 1 The claimant is able to understand, remember, and carry out simple, routine tasks and instructions. He is able to 2 maintain concentration, persistence, and pace on simple routine tasks for the two-hour intervals between regularly 3 scheduled breaks. He needs to be in a predictable environment. He can have no fast-paced work production, 4 such as an assembly line pace. He can have occasionally [sic] and superficial interaction with the public and coworkers 5 and no work around crowds. Instructions should be by demonstration or orally, but not written. Reading should not 6 be an essential function of the job.

7 • Step four: Plaintiff has no past relevant work. 8 • Step five: considering Plaintiff’s RFC, age, education, and work 9 history, Plaintiff can perform work that exists in significant numbers 10 in the national economy, such as cleaner II, church janitor, and 11 laundry aide.22 12 Plaintiff timely requested review of the ALJ’s decision by the Appeals 13 Council and now this Court.23 14 II. Standard of Review 15 The ALJ’s decision is reversed “only if it is not supported by substantial 16 evidence or is based on legal error” and such error impacted the nondisability 17 determination.24 Substantial evidence is “more than a mere scintilla but less than 18

19 22 AR 17–29. 20 23 AR 1–6. 21 24 Hill v. Astrue, 698 F.3d 1153, 1158 (9th Cir. 2012). See 42 U.S.C. § 405(g); 22 Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir.

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Bluebook (online)
Lawton v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawton-v-dudek-waed-2025.