Leary v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedNovember 18, 2024
Docket3:24-cv-05448
StatusUnknown

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

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 SHANNON L., 8 Plaintiff, CASE NO. C24-5448-BAT 9 v. ORDER REVERSING AND 10 REMANDING COMMISSIONER OF SOCIAL SECURITY, 11 Defendant. 12

13 Plaintiff appeals the ALJ’s decision finding her not disabled. In 2021, Plaintiff applied 14 for benefits alleging disability beginning April, 2020. After conducting a hearing in August, 15 2023, the ALJ issued a decision finding (1) Plaintiff engaged in substantial gainful work activity 16 (SGA) in the fourth quarter of 2021 and July 2023 but as the periods of SGA were brief, the 17 entire period since alleged onset will be considered; (2) ankylosing spondylitis of the SI joints 18 and ulcerative colitis with enteropathic arthropathy are severe impairments; (3) with these 19 impairments, Plaintiff retains the residual functional capacity (RFC) to perform light work with 20 certain additional limitations; and (4) Plaintiff is capable of performing past relevant work as a 21 server and administrative clerk, and is therefore not disabled. 22 Plaintiff contends the Court should remand this matter for further administrative 23 proceedings on the grounds the ALJ erroneously rejected her testimony that pain and fatigue 1 limit her ability to work; misevaluated the opinion of treating nurse practitioner Sydni Wright, 2 ARNP, that Plaintiff must lie down daily due to pain and fatigue and will miss work four days a 3 month; and erroneously found Plaintiff performed SGA during the relevant period. Dkt. 9 at 1-2. 4 For the reasons below, the Court REVERSES the Commissioner’s final decision and

5 REMANDS the matter for further administrative proceedings under sentence four of 42 U.S.C. § 6 405(g). 7 DISCUSSION 8 A. Plaintiff’s Testimony 9 The ALJ found Plaintiff’s medically determinable impairments could reasonably be 10 expected to cause the symptoms she alleged but discounted Plaintiff’s testimony. The ALJ did 11 not find Plaintiff was malingering and was thus required to provide clear and convincing reasons 12 to discount Plaintiff’s testimony. Burrell v. Colvin, 775 F.3d 1133, 113637 (9th Cir. 2014); see 13 also Laborin v. Berryhill, 867 F.3d 1151, 1155 (9th Cir. 2017) (the ALJ must identify “which 14 testimony [the ALJ] found not credible” and explain “which evidence contradicted that

15 testimony.”). The ALJ is not required to “believe every allegation of disabling pain,” Ahearn v. 16 Saul, 988 F.3d 1111, 1116 (9th Cir. 2021) (citing Fair v. Bowen, 885 F.2d 597, 603 (9th Cir. 17 1989)), or to “perform a line-by-line exegesis” of Plaintiff’s testimony. Lambert v. Saul, 980 18 F.3d 1266, 1277 (9th Cir. 2020). “The standard isn’t whether our court is convinced, but instead 19 whether the ALJ’s rationale is clear enough that it has the power to convince.” Smartt v. 20 Kijakazi, 53 F.4th 489, 499 (9th Cir. 2022). 21 At the hearing the ALJ conducted on August 31, 2023, Plaintiff’s lawyer stated Plaintiff: 22 is working right now as she will testify too, and we did send in the paystubs from Sunset Grill, she started that job on June 26th, 2023, 23 and as noted she is over SGA the last two months but as she – and I’m proffering at this point but she will testify that she is missing 1 days of work already. She is calling in sick and as – is very worried that she will not be able to keep this job only two months 2 in. 3 Tr. 39-40. Plaintiff testified she works as a waitress four days a week and her current shift is 4 Saturday to Tuesday from 8:00 am to 2:30 pm. Tr. 41. She stated in the last two months, she 5 “called out” four times, and her employer told her if she continues to call out “we’re going to 6 have to look at your schedule.” Id. Plaintiff testified she cannot work due to insomnia, pain, 7 cramping, nausea, need to use the restroom, exhaustion and need to nap, and that she spends 8 most of her time at home resting because she is tired and in pain from working. Tr. 44. She 9 further stated that since 2019, her pain has grown progressively worse, she takes more pain 10 medication, is exhausted throughout the day, Tr. 45, and has pain “flare ups” lasting a few days 11 or a few weeks that fluctuates but can occur monthly. Tr. 48. Plaintiff further testified she lives 12 in a “mother-in-law” with her parents and that her mother helps her with household chores and 13 shopping. Tr. 56. 14 In October 2023, the ALJ issued a decision noting Plaintiff’s testimony that she was

15 currently working but “had to call in a number of times because of chronic pain and fatigue,” Tr. 16 23; that she indicated she spends her days trying to catch up on sleep or resting due to pain and 17 energy loss caused by working and naps several days on average; and that her fluctuating pain 18 levels and medications cause side effects, and her insomnia and symptoms of ankylosing 19 spondylitis and ulcerative colitis make it difficult for her to hold even part-time work. Id. at 23- 20 24. However, the ALJ discounted Plaintiff’s testimony as inconsistent with the “medical 21 evidence and other evidence of record.” Tr. 24. 22 The ALJ indicated Plaintiff has a history of joint pain in multiple locations since her 23 teenage years and “endorses stiffness of more than an hour in the mornings” and that her pain 1 was relieved by activity but interferes with her sleep causing fatigue. Id. at 24. The ALJ found 2 contrary to Plaintiff’s testimony, the medical record shows Plaintiff can perform less than light 3 work. The ALJ indicated the medical record documents Plaintiff’s impairments to be 4 “sufficiently controlled to allow her to perform work,” and that Plaintiff’s treatment records

5 show her colitis is stable and in remission with Humira. Id. 6 The ALJ noted Plaintiff’s June 2022 treatment note indicated no acute distress or joint 7 problems and no side effects from treatment. Id. The ALJ further noted Plaintiff indicated 8 ongoing morning stiffness and neck, shoulder, and back pain but that she expressed satisfaction 9 with her therapy; had no swelling in her joints; had full range of movement; and little lower body 10 complaints. Tr. 25. In June 2023, the ALJ noted Plaintiff indicated her medications were 11 effective for pain, and she had no breakthrough pain, no side effects and her medications allowed 12 her to be more functional. Id. 13 Additionally, the ALJ noted in July 2023, Plaintiff returned to gainful activity by working 14 as a restaurant server. Tr. 25. An August 2023 provider statement indicated Plaintiff had to call

15 out of work often due to fatigue and pain. The ALJ stated “[h]owever, there are no records for 16 that contemporaneous period to support that the effectiveness of treatment that had maintained 17 through June of that year, and that had allowed her to return to substantial gainful activity had 18 waned.” Tr. 25. 19 Plaintiff contends the ALJ erred. She first argues the ALJ erroneously discounted her 20 testimony based upon “a lack of objective evidence, i.e., no swelling or limitations of range of 21 motion” and contends the ALJ cannot discount a claimant’s pain testimony solely because it is 22 not fully corroborated by objective medical findings, and further contends the ALJ did not 23 “establish a medical basis” for his conclusion the record undermines Plaintiff’s testimony. Dkt. 9 1 at 5-6. This argument does not track with the ALJ’s decision regarding Plaintiff’s pain 2 complaints.

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Leary v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leary-v-commissioner-of-social-security-wawd-2024.