McGiveron v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedAugust 26, 2019
Docket3:19-cv-05114
StatusUnknown

This text of McGiveron v. Commissioner of Social Security (McGiveron 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
McGiveron v. Commissioner of Social Security, (W.D. Wash. 2019).

Opinion

1 2 3 4 5

6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 SAM M., CASE NO. 3:19-cv-5114 MJP-JRC 11 Plaintiff, REPORT AND RECOMMENDATION 12 v. ON PLAINTIFF’S COMPLAINT 13 COMMISSIONER OF SOCIAL NOTING DATE: September 13, 2019 SECURITY, 14 Defendant. 15 This matter has been referred to United States Magistrate Judge J. Richard Creatura 16 pursuant to 28 U.S.C. § 636(b)(1) and Local Magistrate Judge Rule MJR 4(a)(4), and as 17 authorized by Mathews, Secretary of H.E.W. v. Weber, 423 U.S. 261, 271-72 (1976). This matter 18 has been fully briefed. See Dkts. 10, 11, 12. 19 After considering and reviewing the record, the Court finds that the ALJ’s decision is not 20 based on substantial evidence. The ALJ rejected a medical opinion but failed to explain why her 21 opinion, rather than the doctor’s was correct. Additionally, she rejected a psychological opinion 22 because it appeared to be based on plaintiff’s medical impairments rather than his mental health 23 diagnosis, but she did not support her statement with substantial evidence. 24 1 The ALJ failed to provide clear and convincing reasons for rejecting plaintiff’s symptom 2 testimony because she failed to link plaintiff’s testimony with specific evidence that undermined 3 his testimony. The ALJ also failed to demonstrate how plaintiff’s daily activities met the 4 threshold for transferable work skills. Finally, the ALJ overlooked material lay evidence from 5 plaintiff’s former employer regarding his ability to maintain employment.

6 Further proceedings would unnecessarily delay the resolution of this matter and will 7 serve no useful purpose since it is clear that plaintiff would be disabled if the improperly rejected 8 evidence were credited as true. Accordingly, this Court recommends that this matter be reversed 9 and remanded to the Commissioner and that benefits be awarded pursuant to sentence four of 42 10 U.S.C. § 405(g). 11 12 PROCEDURAL HISTORY 13 Plaintiff’s applications for disability insurance (“DIB”) benefits pursuant to 42 U.S.C. § 14 423 (Title II) and Supplemental Security Income (“SSI”) benefits pursuant to 42 U.S.C. §

15 1382(a) (Title XVI) of the Social Security Act were denied initially and following 16 reconsideration. See AR. 73-74; 105-106. Plaintiff’s requested hearing was held before 17 Administrative Law Judge Marilyn S. Mauer (“the ALJ”) on April 12, 2017. See AR. 38. On 18 January 2, 2018, the ALJ issued a written decision in which the ALJ concluded that plaintiff was 19 not disabled pursuant to the Social Security Act. See AR. 12. 20 On January 8, 2019 the Appeals Council denied plaintiff’s request for review, making the 21 written decision by the ALJ the final agency decision subject to judicial review. AR. 1; see 20 22 C.F.R. § 404.981. Plaintiff filed a complaint in this Court seeking judicial review of the ALJ’s 23 24 1 written decision in February 2019. Dkt. 1. Defendant filed the sealed administrative record 2 regarding this matter (“AR.”) on April 23, 2019. Dkt. 8. 3 4 BACKGROUND 5 Plaintiff, Sam M., was born in 1968 and was 44 years old on the alleged disability onset

6 date of October 1, 2013. AR. 75. Plaintiff has a GED and a history of working in a mill. AR. 7 262. Plaintiff stopped working because of his conditions. AR. 261. 8 Plaintiff filed his claim for disability benefits alleging lower back injury, nerve problems, 9 “mental issues,” depression, left-hand finger damage, lung problems, “severe emotional losses,” 10 and neck problems. AR. 75. According to the ALJ, plaintiff has at least the severe impairments 11 of mild cervical degenerative disc disease with mild dextrocurvature, nerve damage left hand, 12 major depressive disorder, anxiety disorder, chronic obstructive pulmonary disease (“COPD”) 13 controlled with medication, and mild lumbar degenerative disc disease. AR. 17. 14

15 STANDARD OF REVIEW 16 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner's denial of 17 social security benefits if the ALJ's findings are based on legal error or not supported by 18 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 19 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). 20 21 DISCUSSION 22 Plaintiff applied for disability benefits alleging mental and physical impairments. In 23 plaintiff’s opening brief, plaintiff raises the following issues: (1) Whether the ALJ provided 24 1 specific and legitimate or clear and convincing reasons to discount the opinions of multiple 2 medical providers; (2) Whether the ALJ gave clear and convincing reasons for rejecting 3 plaintiff’s symptom testimony; (3) Whether the ALJ ignored lay evidence from plaintiff’s former 4 employer; and (4) Whether the ALJ erred in failing to consider the side-effects of prescribed 5 medications. Dkt. 10, p. 1.

6 I. Whether the ALJ Erred in Evaluating the Medical Evidence 7 Plaintiff alleges that the ALJ erred in evaluating several medical opinions. The ALJ must 8 provide “clear and convincing” reasons for rejecting the uncontradicted opinion of either a 9 treating or examining physician or psychologist. Lester v. Chater, 81 F.3d 821, 830 (9th Cir. 10 1996) (citing Embrey v. Bowen, 849 F.2d 418, 422 (9th Cir. 1988). When a treating or examining 11 physician’s opinion is contradicted, that opinion can be rejected “for specific and legitimate 12 reasons that are supported by substantial evidence in the record.” Lester v. Chater, 81 F.3d 821, 13 830-31 (9th Cir. 1996) (citing Andrews v. Shalala, 53 F.3d 1035, 1043 (9th Cir. 1995); Murray v. 14 Heckler, 722 F.2d 499, 502 (9th Cir. 1983)).

15 An examining physician’s opinion is “entitled to greater weight than the opinion of a 16 nonexamining physician.” Lester, 81 F.3d at 830 (citations omitted); see also 20 C.F.R. § 17 404.1527(c)(1)(“Generally, we give more weight to the opinion of a source who has examined 18 you than to the opinion of a source who has not examined you”). “In order to discount the 19 opinion of an examining physician in favor of the opinion of a nonexamining medical advisor, 20 the ALJ must set forth specific, legitimate reasons that are supported by substantial evidence in 21 the record.” Nguyen v. Chater, 100 F.3d 1462, 1466 (9th Cir. 1996) (citing Lester, 81 F.3d at 22 831).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mathews v. Weber
423 U.S. 261 (Supreme Court, 1976)
Turner v. Commissioner of Social Security
613 F.3d 1217 (Ninth Circuit, 2010)
Baella-Silva v. Hulsey
454 F.3d 5 (First Circuit, 2006)
United States v. Maher
454 F.3d 13 (First Circuit, 2006)
United States v. Maurice L. Ziegler
1 F.3d 1044 (Tenth Circuit, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
McGiveron v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcgiveron-v-commissioner-of-social-security-wawd-2019.