O'Connell v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedSeptember 29, 2025
Docket3:25-cv-05303
StatusUnknown

This text of O'Connell v. Commissioner of Social Security (O'Connell 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
O'Connell v. Commissioner of Social Security, (W.D. Wash. 2025).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 DAWN O., 8 Plaintiff, CASE NO. C25-5303-BAT 9 v. ORDER REVERSING AND REMANDING FOR AN AWARD OF 10 COMMISSIONER OF SOCIAL SECURITY, BENEFITS 11 Defendant. 12 13 Plaintiff Dawn O. seeks review of the denial of her application for Supplemental Security 14 Income. She argues that the ALJ erred in evaluating her testimony and that remand for an award 15 of benefits is the appropriate remedy for this error. Dkt. 10. The Court agrees and therefore 16 REVERSES the Commissioner’s final decision and REMANDS the matter for an immediate 17 award of benefits. 18 BACKGROUND 19 Plaintiff is currently 46 years old and was 40 years old on her alleged onset date; she has 20 a limited education and no past relevant work. Tr. 823. Plaintiff applied for benefits in October 21 2019; she later amended her claim to allege a closed period of disability from October 8, 2019, to 22 May 31, 2021. Tr. 87-88; 392. After her application was denied initially and on reconsideration, 23 the ALJ conducted a hearing and, on June 29, 2022, issued a decision finding plaintiff not 1 disabled. Tr. 15-30. Plaintiff sought judicial review, and, on September 6, 2023, this Court 2 reversed the ALJ’s decision and remanded the case for further administrative proceedings. Tr. 3 908-13. On remand, the ALJ conducted another hearing and, on February 6, 2025, issued a new 4 decision finding plaintiff not disabled. Tr. 810-25. Plaintiff now seeks review of the February

5 2025 decision. 6 THE ALJ’S DECISION 7 Utilizing the five-step disability evaluation process,1 the ALJ found that plaintiff had 8 engaged in substantial gainful activity since June 1, 2021, but had not engaged in substantial 9 gainful activity from October 8, 2019, through May 31, 2021; she had the following severe 10 impairments: premenstrual dysphoric disorder (PMDD), post-traumatic stress disorder (PTSD), 11 and major depressive disorder; and these impairments did not meet or equal the requirements of 12 a listed impairment. Tr. 813-15. The ALJ found that plaintiff had the residual functional capacity 13 to perform a full range of work at all exertional levels but with the following nonexertional 14 limitations: she could understand, remember, and carry out detailed but not complex instructions;

15 perform predictable tasks but not in a fast-paced, production-type environment; with exposure to 16 occasional workplace changes and occasional interaction with supervisors, coworkers, and the 17 general public, but not in a team-oriented environment. Tr. 816. The ALJ found that plaintiff had 18 no past relevant work but, as there are jobs that exist in significant numbers in the national 19 economy that plaintiff could have performed during the relevant period, she was not disabled 20 since October 8, 2019. Tr. 823-25. 21 22 23

1 20 C.F.R. §§ 404.1520, 416.920. 1 DISCUSSION 2 The Court will reverse the ALJ’s decision only if it is not supported by substantial 3 evidence in the record as a whole or if the ALJ applied the wrong legal standard. Molina v. 4 Astrue, 674 F.3d 1104, 1110 (9th Cir. 2012). The ALJ’s decision may not be reversed on account

5 of an error that is harmless. Id. at 1111. The Court may neither reweigh the evidence nor 6 substitute its judgment for that of the Commissioner. Thomas v. Barnhart, 278 F.3d 947, 954 7 (9th Cir. 2002). Where the evidence is susceptible to more than one rational interpretation, the 8 Court must uphold the Commissioner’s interpretation. Id. 9 A. Plaintiff’s testimony 10 Plaintiff’s sole claim of error is in the ALJ’s assessment of her testimony about the 11 effects of her PMDD during the relevant period. Dkt. 10 at 1. This is the same error that was the 12 basis for this Court’s previous reversal and remand for further administrative proceedings. Tr. 13 910-11. Plaintiff argues that the ALJ failed to correct the error on remand and again committed 14 error in rejecting her testimony. Dkt. 10 at 1. The Court agrees.

15 Where, as here, the ALJ did not find plaintiff was malingering, the ALJ must provide 16 clear and convincing reasons to reject her testimony. See Vertigan v. Halter, 260 F.3d 1044, 17 1049 (9th Cir. 2001). An ALJ does this by making specific findings supported by substantial 18 evidence. “General findings are insufficient; rather, the ALJ must identify what testimony is not 19 credible and what evidence undermines the claimant’s complaints.” Lester v. Chater, 81 F.3d 20 821, 834 (9th Cir. 1996). In other words, an ALJ’s finding that a claimant’s testimony is not 21 credible must be “sufficiently specific to allow a reviewing court to conclude the adjudicator 22 rejected the claimant’s testimony on permissible grounds and did not arbitrarily discredit a 23 claimant’s testimony regarding pain.” Brown-Hunter v. Colvin, 806 F.3d 487, 493 (9th Cir. 1 2015). A conclusory statement rejecting a claimant’s testimony that fails to identify specifically 2 which statements the ALJ found not credible and why is not sufficient to reject a claimant’s 3 testimony, even when that statement is followed by a summary of the evidence. Id. 4 Plaintiff’s allegations center on the effects of her PMDD. She alleges that during the

5 relevant period, the symptoms of her PMDD, including anger, disruptive outbursts, and verbally 6 hostile behavior, prevented her from working. Dkt. 10 at 2-3; Tr. 94-96. After a suicide attempt 7 in February 2021, plaintiff was diagnosed with PMDD and began taking a new medication to 8 treat her PMDD symptoms. Tr. 86. Plaintiff alleges that with this new medication, her symptoms 9 improved to such an extent that she was able to begin working on June 3, 2021, thus leading to 10 her claim for a closed period of disability ending on May 31, 2021. Tr. 86-87. 11 The ALJ found that evidence from the treatment record showed that plaintiff was not as 12 restricted as she alleged. Tr. 818. The ALJ summarized treatment records from the relevant 13 period, including therapy notes, a consultative psychological examination, treatment notes from 14 plaintiff’s primary care providers, and records from plaintiff’s hospitalization after her February

15 2021 suicide attempt. Tr. 818-20. However, the ALJ did not connect the records in this summary 16 to plaintiff’s testimony or explain how the records undermined her allegations. An ALJ 17 “‘providing a summary of medical evidence . . . is not the same as providing clear and 18 convincing reasons for finding the claimant’s symptom testimony not credible.’” Lambert v. 19 Saul, 980 F.3d 1266, 1278 (9th Cir. 2020) (quoting Brown-Hunter, 806 F.3d at 494). Even where 20 a reviewing court could identify inconsistencies with the claimant’s testimony based on the 21 ALJ’s summary of the evidence, such reasoning is unavailing, as the court “‘is constrained to 22 review the reasons the ALJ asserts.’” Id. (quoting Brown-Hunter, 806 F.3d at 494). Because the 23 ALJ failed to provide reasons for discounting plaintiff’s testimony based on the records he 1 summarized, the Court cannot determine whether the ALJ rejected plaintiff’s claims on 2 permissible grounds.

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Molina v. Astrue
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Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Kim Brown-Hunter v. Carolyn W. Colvin
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Karen Lambert v. Andrew Saul
980 F.3d 1266 (Ninth Circuit, 2020)

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