McDuffie-Williams v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 26, 2024
Docket3:23-cv-05623
StatusUnknown

This text of McDuffie-Williams v. Commissioner of Social Security (McDuffie-Williams 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
McDuffie-Williams v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 KAYE M., CASE NO. 3:23-cv-05623-GJL 11 Plaintiff, v. ORDER ON PLAINTIFF’S 12 COMPLAINT COMMISSIONER OF SOCIAL 13 SECURITY, 14 Defendant.

15 This Court has jurisdiction pursuant to 28 U.S.C. § 636(c), Fed. R. Civ. P. 73 and Local 16 Magistrate Judge Rule MJR 13. See also Consent to Proceed Before a United States Magistrate 17 Judge, Dkt. 2. This matter has been fully briefed. See Dkts.9–15. 18 After considering and reviewing the record, the Court concludes the Administrative Law 19 Judge (“ALJ”) erred in discounting Plaintiff’s subjective symptom testimony. The Court 20 accordingly REVERSES and REMANDS this matter for further proceedings. 21 I. PROCEDURAL HISTORY 22 Plaintiff filed for Supplemental Security Income (“SSI”) benefits on February 7, 2020, 23 alleging in her application a disability onset date of April 20, 2010. Administrative Record 24 1 (“AR”) 122–23, 140. Plaintiff’s application was denied initially and following reconsideration. 2 See AR 137, 159. After Plaintiff’s requested hearing was held before the ALJ (AR 41–86), the 3 ALJ issued an unfavorable decision finding Plaintiff not disabled. See AR 161–80. In September 4 2021, the Appeals Council remanded the ALJ’s decision. AR 181–86. After the ALJ held a

5 hearing on remand in February 2023 (AR 87–120), the ALJ again issued an unfavorable decision 6 in March 2023 finding Plaintiff not disabled. AR 17–40. The Appeals Council denied Plaintiff’s 7 request for review, making the March 2023 decision by the ALJ the final agency decision subject 8 to judicial review. AR 1–7; see 20 C.F.R. § 416.1481. Plaintiff filed a complaint in this Court 9 and appealed the ALJ’s March 2023 decision. See Dkt. 5. 10 II. BACKGROUND 11 Plaintiff was born in 1981 and was 38 years old on the alleged date of disability onset of 12 April 20, 2010. See AR 31. Plaintiff has at least a high school education and previously worked 13 as a sorter/pricer, fast food worker, automobile service station attendant, and cashier. Id. 14 According to the ALJ, Plaintiff has the severe impairments of seizure disorder, cannabis use

15 disorder, alcohol use disorder, amphetamine use disorder, bipolar disorder, post-traumatic stress 16 disorder (“PTSD”), personality disorder, generalized anxiety disorder, and major depressive 17 disorder. AR 23. However, the ALJ concluded Plaintiff is not disabled because she has the 18 residual functional capacity (“RFC”) to perform a full range of work with nonexertional 19 limitations. AR 26. 20 III. DISCUSSION 21 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of 22 social security benefits if the ALJ’s findings are based on legal error or not supported by 23

24 1 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 2 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). 3 Plaintiff raises the following issues in her Opening Brief: (1) whether the ALJ properly 4 evaluated Dr. Wilkinson’s medical opinion, (2) whether the ALJ properly evaluated her

5 subjective testimony, and (3) whether the ALJ erred at step one of the sequential evaluation 6 process. See Dkt. 9 at 3–16. 7 A. Medical Opinion Evidence 8 Plaintiff contends the ALJ erred in evaluating Dr. Wilkinson’s medical opinion. Dkt. 9 at 9 3–9. 10 In a January 2020 evaluation, Dr. Wilkinson opined Plaintiff is markedly limited in: (1) 11 performing activities within a schedule, maintaining regular attendance, and being punctual 12 within customary tolerances without special supervision, and (2) adapting to changes in a routine 13 work setting. AR 487. Dr. Wilkinson also opined Plaintiff is severely limited in (1) maintaining 14 appropriate behavior in a work setting and (2) completing a normal work day and work week

15 without interruptions from psychologically based symptoms. AR 487–88. Dr. Wilkinson overall 16 found Plaintiff severely limited. AR 488. 17 The ALJ first discounted Dr. Wilkinson’s opinion because he provided it prior to 18 Plaintiff’s February 7, 2020, filing date. AR 28. That Dr. Wilkinson completed his evaluation a 19 month before Plaintiff filed her application was error, as the ALJ must consider all of the 20 medical opinion evidence of record. 20 C.F.R. § 416.920c. 21 Next, the ALJ found Dr. Wilkinson’s opinion unsupported by his own treatment notes 22 and inconsistent with other medical evidence in the record. AR 28. ALJs must consider every 23 medical opinion in the record and evaluate each opinion’s persuasiveness, with the two most

24 1 important factors being “supportability” and “consistency.” Woods v. Kijakazi, 32 F.4th 785, 791 2 (9th Cir. 2022); 20 C.F.R. § 416.920c(a). Supportability concerns how a medical source supports 3 a medical opinion with relevant evidence, while consistency concerns how a medical opinion is 4 consistent with other evidence from medical and nonmedical sources. See id.; 20 C.F.R. §

5 416.920c(c)(1), (c)(2). Under the new regulations, “an ALJ cannot reject an examining or 6 treating doctor’s opinion as unsupported or inconsistent without providing an explanation 7 supported by substantial evidence.” Woods, 32 F.4th at 792. 8 Here, the ALJ noted Dr. Wilkinson’s mental status examination produced “rather benign” 9 findings that do not support his proposed limitations. AR 28. Plaintiff points out Dr. Wilkinson 10 performed a detailed interview and argues the ALJ’s finding substitutes the physician’s opinion 11 in favor of a lay interpretation. See Dkt. 9 at 5 (citing AR 491–92). 12 The ALJ’s assessment, however, is reasonable, as neither Dr. Wilkinson’s interview 13 notes nor his exam findings explain why Plaintiff is markedly and severe limited in certain work 14 functionalities. See AR 485–93. The ALJ pointed out that though Plaintiff reported as depressed

15 during the examination, she was also alert and cooperative, her thought process and fund of 16 knowledge were within normal limits, and she had no hallucinations or delusional thinking. AR 17 28 (citing AR 489). The record shows Plaintiff “stammered rather than stuttered,” but was still 18 able to express herself in a “communicative manner.” AR 489. The ALJ also pointed out 19 Plaintiff had fair memory and was able to complete concentration tasks successfully, though she 20 was noted as “quite slow” and had to use her fingers to subtract in one of her exercises. AR 28 21 (citing AR 489). 22 Overall, it is not clear from Dr. Wilkinson’s evaluation, which indicates Plaintiff’s 23 presentation was substantially normal, how the physician found her markedly to severely limited

24 1 in adhering to a schedule, adapting to changes in a work setting, or completing work without 2 interruption. Therefore, in discounting Dr. Wilkinson’s opinion for its lack of support, the ALJ 3 did not err. 4 The ALJ also discounted Dr.

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