McNiel v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJuly 10, 2024
Docket2:23-cv-01771
StatusUnknown

This text of McNiel v. Commissioner of Social Security (McNiel 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
McNiel 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 JENNIFER M., CASE NO. 2:23-CV-1771-DWC 11 Plaintiff, v. ORDER REVERSING AND 12 REMANDING THE COMMISSIONER OF SOCIAL COMMISSIONER’S DECISION 13 SECURITY, 14 Defendant.

15 Plaintiff filed this action, pursuant to 42 U.S.C. § 405(g), for judicial review of 16 Defendant’s denial of her application for supplemental security income (“SSI”).1 The parties 17 agree the Administrative Law Judge (“ALJ”) committed reversible error and this matter should 18 be remanded. The parties dispute whether this matter should be remanded for an award of 19 benefits or for further administrative proceedings. After consideration the record, the Court finds 20 there are outstanding issues that must be resolved. Accordingly, this matter is reversed and 21 22 23 1 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73 and Local Rule MJR 13, the parties 24 have consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 2. 1 remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the Commissioner of Social 2 Security for further administrative proceedings. 3 I. Factual and Procedural History 4 On February 14, 2018, Plaintiff filed an application for SSI, alleging disability beginning

5 January 20, 2018. See Dkt. 8, Administrative Record (“AR”) 15. The application was denied 6 upon initial administrative review and on reconsideration. See AR 15. After holding an 7 administrative hearing, ALJ Glenn Meyers issued a decision on November 6, 2019 finding 8 Plaintiff not disabled. See AR 15-32. Plaintiff’s request for review of the ALJ’s decision was 9 denied by the Appeals Council, making the ALJ’s decision the final decision of the 10 Commissioner. See AR 1-5; 20 C.F.R. § 404.981, § 416.1481. 11 Plaintiff appealed to the United States District Court for the Western District of 12 Washington (“District Court”); the District Court remanded the case to the Commissioner for 13 further proceedings. AR 641-53; see also Jennifer M. v. Commissioner of Social Security, 2:20- 14 1704-DWC (W.D. Wash. July 27, 2021). On remand from the District Court, the Appeals

15 Council vacated the November 2019 decision and remanded the case to ALJ Meyers for further 16 proceedings. See AR 638. ALJ Meyers held an additional administrative hearing and, on August 17 9, 2023, issued a decision finding Plaintiff not disabled. See AR 555-72. Plaintiff now appeals 18 ALJ Meyer’s August 2023 decision, which is the final decision of the Commissioner. 19 In the Opening Brief, Plaintiff maintains the ALJ erred by: (1) improperly evaluating 20 Plaintiff’s testimony; and (2) failing to support the Step Five findings with substantial evidence. 21 Dkt. 10. 22 23

24 1 II. Standard of Review 2 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of 3 social security benefits if the ALJ’s findings are based on legal error or not supported by 4 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th

5 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). 6 III. Discussion 7 Plaintiff and Defendant agree the ALJ committed reversible error. Dkts. 10, 14, 15. 8 However, Defendant asserts the ALJ did not err in his consideration of Plaintiff’s subjective 9 symptom testimony. Dkt. 14. Rather, the ALJ only erred in his consideration of Step Five. Id. 10 Defendant requests this matter be remanded to the Commissioner for further administrative 11 proceedings. Id. Plaintiff argues this matter should be remanded for an immediate award of 12 benefits. Dkts. 10, 15.2 13 The Court may remand a case “either for additional evidence and findings or to award 14 benefits.” Smolen v. Chater, 80 F.3d 1273, 1292 (9th Cir. 1996). Generally, when the Court

15 reverses an ALJ’s decision, “the proper course, except in rare circumstances, is to remand to the 16 agency for additional investigation or explanation.” Benecke v. Barnhart, 379 F.3d 587, 595 (9th 17 Cir. 2004) (citations omitted). However, the Ninth Circuit created a “test for determining when 18 evidence should be credited and an immediate award of benefits directed[.]” Harman v. Apfel, 19 211 F.3d 1172, 1178 (9th Cir. 2000). Specifically, under this “credit-as-true” test, benefits should 20 be awarded where: 21

22 2 Defendant asserts the ALJ did not commit harmful error in his consideration of Plaintiff’s subjective symptom testimony. Dkt. 14. As this matter must be remanded due to the ALJ’s error at Step Five, the Court 23 declines to determine whether the ALJ erred in his consideration of Plaintiff’s testimony. Rather, as discussed below, the Court finds this matter should be remanded for further proceedings and, therefore, on remand, the ALJ 24 shall take additional testimony and evidence from Plaintiff and issue a new decision. 1 (1) the ALJ has failed to provide legally sufficient reasons for rejecting [the claimant’s] evidence, (2) there are no outstanding issues that must be resolved 2 before a determination of disability can be made, and (3) it is clear from the record that the ALJ would be required to find the claimant disabled were such evidence 3 credited.

4 Smolen, 80 F.3d 1273 at 1292; McCartey v. Massanari, 298 F.3d 1072, 1076-77 (9th Cir. 2002). 5 An ALJ’s errors are relevant, however, only to the extent they impact the underlying 6 question of the Plaintiff’s disability. Strauss v. Commissioner of the Social Sec. Admin., 635 F.3d 7 1135, 1138 (9th Cir. 2011). “A claimant is not entitled to benefits under the statute unless the 8 claimant is, in fact, disabled, no matter how egregious the ALJ’s errors may be.” Id. (citing 9 Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345, 357 (7th Cir. 2005)). Therefore, even if the 10 “credit-as-true” conditions are satisfied, a court should nonetheless remand the case if “an 11 evaluation of the record as a whole creates serious doubt that a claimant is, in fact, disabled.” 12 Garrison v. Colvin, 759 F.3d 995, 1021 (9th Cir. 2014) (citing Connett v. Barnhart, 340 F.3d 13 871, 876 (9th Cir. 2004)). 14 In this case, Plaintiff has failed to satisfy prongs 2 and 3 of the credit-as-true test.

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