Maehler v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 3, 2024
Docket3:23-cv-05384
StatusUnknown

This text of Maehler v. Commissioner of Social Security (Maehler 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
Maehler 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 JOSHUA J. M., 8 Plaintiff, Case No. C23-5384 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 his application for Disability Insurance Benefits 14 (DIB). Plaintiff contends the ALJ erred at step five and by rejecting his symptom testimony. 15 Dkt. 8.1 As discussed below, the Court REVERSES the Commissioner’s final decision and 16 REMANDS the matter for further administrative proceedings under sentence four of 42 U.S.C. § 17 405(g). 18 BACKGROUND 19 Plaintiff is 41 years old, has at least a high school education, and has worked as a medical 20 service technician, combat rifle crew member, management trainee, and manager, retail store. 21 Admin. Record (AR) 39. In August 2020, Plaintiff applied for benefits, alleging disability as of 22

1 Plaintiff’s Opening Brief does not entirely comply with the briefing requirements provided in the Court’s 23 Scheduling Order, as Plaintiff did not list the alleged errors on the first page of the brief. See Dkts. 7 at 2; 8 at 1. In the future, counsel shall take care to review and comply with the Court’s briefing requirements. ORDER REVERSING DENIAL OF 1 August 31, 2014. AR 83, 94. Plaintiff’s application was denied initially and on reconsideration. 2 AR 90, 118. The ALJ conducted a hearing in December 2021 (AR 46–81) and issued a decision 3 in March 2022 finding Plaintiff not disabled from his alleged onset date of August 31, 2014, 4 through his date last insured of December 31, 2019. AR 22–45. 5 DISCUSSION 6 The Court may reverse the ALJ’s decision only if it is legally erroneous or not supported 7 by substantial evidence of record. Ford v. Saul, 950 F.3d 1141, 1154 (9th Cir. 2020). The Court 8 must examine the record but cannot reweigh the evidence or substitute its judgment for the 9 ALJ’s. Thomas v. Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When evidence is susceptible to 10 more than one interpretation, the Court must uphold the ALJ’s interpretation if rational. Ford,

11 950 F.3d at 1154. Also, the Court “may not reverse an ALJ’s decision on account of an error 12 that is harmless.” Molina v. Astrue, 674 F.3d 1104, 1111 (9th Cir. 2012). 13 1. Step Five 14 Plaintiff contends the ALJ erred at step five by failing to reconcile the inconsistency 15 between the testimony of the vocational expert (VE) and the Dictionary of Occupational Titles 16 (DOT), and by relying on the VE’s testimony. Dkt. 8 at 4–8. 17 At step five of the sequential evaluation process, the ALJ has the burden of 18 determining whether “the claimant can perform a significant number of other jobs in the 19 national economy.” See Ford, 950 F.3d at 1149. If the claimant is not able to do so, the 20 ALJ must find the claimant disabled. Id. The ALJ can meet the burden of showing that

21 there is other work in “significant numbers” in the national economy by utilizing the 22 testimony of a vocational expert (VE). See Lounsburry v. Barnhart, 468 F.3d 1111, 1114 23 (9th Cir. 2006). An ALJ may not “rely on a vocational expert’s testimony regarding the ORDER REVERSING DENIAL OF 1 requirements of a particular job without first inquiring whether or not the testimony 2 conflicts with the Dictionary of Occupational Titles [DOT].” Massachi v. Astrue, 486 3 F.3d 1149, 1152 (9th Cir. 2007). “When there is an apparent conflict between the 4 vocational expert’s testimony and the DOT—for example, expert testimony that a 5 claimant can perform an occupation involving DOT requirements that appear more than 6 the claimant can handle—the ALJ is required to reconcile the inconsistency.” Zavalin v. 7 Colvin, 778 F.3d 842, 846 (9th Cir. 2015) (citing Massachi, 486 F.3d at 1153–54). “The 8 ALJ must ask the expert to explain the conflict and ‘then determine whether the 9 vocational expert’s explanation for the conflict is reasonable’ before relying on the 10 expert’s testimony to reach a disability determination.” Id.

11 During the hearing, the ALJ asked the VE what jobs are available to an individual like 12 Plaintiff who, in relevant part, is limited to light or sedentary work with occasional overhead 13 reaching with the right dominant arm and occasional superficial interaction with the public and 14 coworkers. AR 73, 75–77. The VE provided the ALJ six jobs: (1) marker (DOT 209.587-034), 15 (2) assembler, small products II (DOT 739.687-030), (3) mail sorter (DOT 209.687-026), (4) 16 document preparer (DOT 249.587-018), (5) escort vehicle driver (DOT 919.663-022), and (6) 17 surveillance system monitor (DOT 379.367-010). AR 77–78. The ALJ then asked the VE if any 18 of his testimony was “inconsistent with the DOT.” AR 79. The VE replied his testimony was 19 not. Id. The ALJ then asked the following: “Now, I gave you limitations that asked you to 20 differentiate between . . . types of reaching, about the workplace environment, contact with

21 others . . . . Assuming that those things are not directly addressed by the DOT, what did you rely 22 on for your testimony?” Id. The VE replied that he relied on his professional experience. Id. 23 At step five, the ALJ adopted the jobs the VE provided. AR 39–40. The ALJ explained: ORDER REVERSING DENIAL OF 1 Although the vocational expert’s testimony is inconsistent with the information contained in the Dictional of Occupational Titles, there is a reasonable explanation 2 for the discrepancy. The vocational expert testified regarding limitations regarding overhead reaching . . . none of which are contemplated in the Dictionary of 3 Occupational Titles. For that testimony, the vocational expert relied on his education, experience, and expertise . . . and the undersigned finds his testimony 4 persuasive.

5 AR 40. 6 Plaintiff disputes the ALJ’s statement that the DOT does not contemplate overhead 7 reaching, and instead argues that the inconsistency needing resolution is between five of the six 8 jobs the VE provided, which require overhead reaching frequently or constantly, and the 9 occasional reaching limitation the ALJ included in his hypotheticals and in the RFC assessment. 10 Dkt. 8 at 6–7; AR 31, 73, 75. Therefore, Plaintiff argues, the ALJ should have further inquired 11 the VE regarding this discrepancy. Dkt. 8 at 7. 12 The Court notes the ALJ did ask the VE if there were any inconsistencies between 13 his testimony and the DOT, so in that regard the ALJ satisfied part of his duty. See AR 14 79. However, by failing to acquire a “reasonable explanation for the apparent conflict” 15 between the reaching frequency in the ALJ’s assessment and the jobs the VE provided 16 and the ALJ adopted in his decision, the ALJ erred. See Zavalin, 778 F.3d at 846. An 17 explanation is necessary in this case because “[s]ignificant limitations of reaching or 18 handling . . . may eliminate a large number of occupations a person could otherwise do. 19 Varying degrees of limitations would have different effects, and the assistance of a 20 [vocational specialist] may be needed to determine the effects of the limitations.” Social 21 Security Ruling (SSR) 85-15.

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Molina v. Astrue
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Carlos Gutierrez v. Commissioner of Social Securit
740 F.3d 519 (Ninth Circuit, 2014)
Igor Zavalin v. Carolyn W. Colvin
778 F.3d 842 (Ninth Circuit, 2015)
Michelle Ford v. Andrew Saul
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81 F.3d 821 (Ninth Circuit, 1995)
Trevizo v. Berryhill
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Bluebook (online)
Maehler v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maehler-v-commissioner-of-social-security-wawd-2024.