Niemann v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedMay 30, 2025
Docket3:24-cv-05778
StatusUnknown

This text of Niemann v. Commissioner of Social Security (Niemann 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
Niemann v. Commissioner of Social Security, (W.D. Wash. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 LITA N., Case No. 3:24-cv-05778-TLF 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S ACTING COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, 10 Defendant. 11 12 Plaintiff filed this action under 42 U.S.C. § 405(g) for judicial review of 13 defendant’s denial of plaintiff’s application for supplemental security income (“SSI”). 14 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule 15 MJR 13, the parties have consented to have this matter heard by the undersigned 16 Magistrate Judge. Dkt. 2. Plaintiff challenges the ALJ’s decision finding that plaintiff was 17 not disabled. Dkt. 4, Complaint. 18 On July 12, 2021, plaintiff filed an application for child benefits, and SSI, alleging 19 a disability onset date of March 3, 1993. On March 13, 2024, a hearing was conducted 20 by ALJ Evangeline Mariano-Jackson. AR 42-66. At the hearing, plaintiff amended the 21 onset date to May 12, 2021, through her representative, and withdrew the application 22 for child benefits. AR 18, 47-49. On April 9, 2024, the ALJ issued a decision finding 23 plaintiff did not meet the criteria for disability benefits. 15-41. 24 1 The ALJ determined plaintiff had the following severe impairments: somatic 2 symptom syndrome, chronic pain, left cubital tunnel syndrome, mild scoliosis, 3 posttraumatic stress disorder (PTSD), generalized anxiety disorder, major depression, 4 and attention deficit hyperactivity disorder (ADHD). AR 21. The ALJ determined plaintiff

5 had the residual functional capacity (“RFC”) to perform light work as defined in 20 6 C.F.R. 404.1567(b) and 416.967(b) with the following additional limitations: 7 She can stand and/or walk for 6 hours in an 8-hour day and sit for 6 hours in an 8-hour workday; can occasionally climb ladders, ropes, and scaffolds; can 8 frequently but not constantly reach overhead with bilateral upper extremities; can never be exposed to vibration; can never work at unprotected heights or around 9 moving mechanical parts or heavy machinery; can understand, remember, and carry out simple, routine, and repetitive tasks involving only simple work-related 10 decisions and occasional decision-making changes in the work setting; can tolerate occasional brief and superficial interaction with coworkers; and is limited 11 to performing work requiring no public contact.

12 AR 24. The ALJ determined plaintiff could perform the requirements of the following 13 representative occupations: Marker (DOT 209.587-034, light, SVP 2), Router (DOT 14 222.587-038, light, SVP2), Collator operator (DOT 208.685-010, light, SVP 2). AR 34. 15 STANDARD 16 The Court may set aside the Commissioner's denial of Social Security benefits if 17 the ALJ's findings are based on legal error or not supported by substantial evidence in 18 the record as a whole. Revels v. Berryhill, 874 F.3d 648, 654 (9th Cir. 2017) (internal 19 citations omitted). Substantial evidence is “‘such relevant evidence as a reasonable 20 mind might accept as adequate to support a conclusion.’” Biestek v. Berryhill, 139 S. Ct. 21 1148, 1154 (2019) (internal citations omitted). The Court must consider the 22 administrative record as a whole. Garrison v. Colvin, 759 F.3d 995, 1009 (9th Cir. 23 2014). The Court also must weigh both the evidence that supports and evidence that 24 1 does not support the ALJ’s conclusion. Id. The Court may not affirm the decision of the 2 ALJ for a reason upon which the ALJ did not rely. Id. Rather, only the reasons identified 3 by the ALJ are considered in the scope of the Court’s review. Id. 4 DISCUSSION

5 1. Medical evidence. 6 Plaintiff argues that the ALJ erred in evaluating the medical opinions of Dr. Alysa 7 Ruddell, Ph.D. and Dr. Renee Eisenhauer, Ph.D. Dkt. 9 at 3-9. 8 The Commissioner “will not defer or give any specific evidentiary weight . . . to 9 any medical opinion(s) . . . including those from [the claimant’s] medical sources.” 20 10 C.F.R. §§ 404.1520c(a), 416.920c(a). The ALJ must nonetheless explain with specificity 11 how he or she considered the factors of supportability and consistency in evaluating the 12 medical opinions. 20 C.F.R. §§ 404.1520c(a)–(b), 416.920c(a)–(b). 13 Under the 2017 regulations, 14 an ALJ cannot reject an examining or treating doctor's opinion as unsupported or inconsistent without providing an explanation supported by 15 substantial evidence. The agency must “articulate ... how persuasive” it finds “all of the medical opinions” from each doctor or other source, 20 16 C.F.R. § 404.1520c(b), and “explain how [it] considered the supportability and consistency factors” in reaching these findings, id. § 404.1520c(b)(2). 17 Id. 18 • Dr. Alysa Ruddell, Ph.D. and Dr. Renee Eisenhauer, Ph.D., 2021 opinions 19 On February 25, 2021, Dr. Ruddell examined plaintiff and completed a 20 psychological/ psychiatric evaluation. AR 481-85. She diagnosed plaintiff with anxiety 21 and depression with a severity rating of four (marked). AR 482. She also assessed 22 PTSD and substance use: cannabis. Id. She completed a medical source statement and 23 opined marked limitations in the following basic work activities: learn new tasks, adapt 24 1 to changes in a routine work setting, complete a normal workday and work week without 2 interruptions from psychologically based symptoms, and set realistic goals and plan 3 independently. AR 483. 4 She opined moderate limitations in every other basic work activity and assigned

5 an overall severity rating of marked. Id. She conducted a mental status exam. AR 484. 6 The ALJ determined that Dr. Ruddell’s opinion was not persuasive because it 7 was expressed in a check-box format, the limitations were not well supported or 8 explained, or consistent with mental status exam findings and other evidence of record. 9 AR 32 10 As for the ALJ’s determination that Dr. Ruddell’s opinion was unpersuasive 11 because it was a check-box format, a check-box form may be used by medical 12 professionals and should only be discounted if the form is unsupported, or unexplained 13 and not clear. Garrison v. Colvin, 759 F.3d 995, 1013 (9th Cir. 2014)). 14 Here Dr. Ruddell conducted a clinical interview, indicated an

15 assessment/diagnosis with explanations, conducted a mental status exam and noted 16 explanations, and administered an evaluation questionnaire. AR 481-85. This is not 17 simply a check-box evaluation. The ALJ’s decision on this point is not supported by 18 substantial evidence. 19 As for the ALJ’s second reason, an ALJ may reject an opinion for internal 20 inconsistency. Rollins v. Massanari, 261 F.3d 853, 856 (9th Cir. 2001). Yet the ALJ 21 must consider the context of the opinion in the record, including observation and 22 treatment notes. Burrell v.

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Niemann v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/niemann-v-commissioner-of-social-security-wawd-2025.