Olson v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedNovember 21, 2024
Docket3:24-cv-05351
StatusUnknown

This text of Olson v. Commissioner of Social Security (Olson 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
Olson v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

1 2 3 4

5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 CRYSTAL O., 8 Plaintiff, CASE NO. C24-5351-BAT 9 v. ORDER AFFIRMING THE COMMISSIONER AND DISMISSING 10 COMMISSIONER OF SOCIAL SECURITY, THE CASE WITH PREJUDICE 11 Defendant. 12 13 Plaintiff Crystal O. seeks review of the denial of her application for Supplemental 14 Security Income. She argues that the ALJ erred in evaluating the medical opinions, plaintiff’s 15 testimony, and the lay witness evidence; she seeks remand for an award of benefits or, in the 16 alternative, remand for further administrative proceedings before a different ALJ. Dkt. 2. For the 17 reasons below, the Court AFFIRMS the Commissioner’s final decision and DISMISSES the 18 case with prejudice. 19 BACKGROUND 20 Plaintiff is currently 44 years old, has completed a GED, and has no past relevant work. 21 Tr. 639. She applied for benefits in February 2017, alleging disability as of December 1, 2015. 22 Tr. 256. At the February 2019 hearing she amended her alleged onset date to February 21, 2017, 23 the application date, but at the October 2023 hearing counsel stated that the correct alleged onset date is December 16, 2015. Tr. 42-42, 659. In September 2019, the ALJ issued a decision finding 1 2 plaintiff not disabled. Tr. 21-32. Plaintiff sought judicial review, and this court reversed that 3 decision and remanded the case for further administrative proceedings. Tr. 721-34. In January 4 2024, the ALJ issued a second decision finding plaintiff not disabled. Tr. 616-40. Plaintiff now

5 seeks review of the second unfavorable decision. 6 THE ALJ’S DECISION 7 Utilizing the five-step disability evaluation process,1 the ALJ found plaintiff had not 8 engaged in substantial gainful activity since the application date; she had the following severe 9 impairments: post-traumatic stress disorder (PTSD), major depressive disorder, generalized 10 anxiety disorder, panic disorder, and agoraphobia; and these impairments did not meet or equal 11 the requirements of a listed impairment. Tr. 619-20. The ALJ found plaintiff had the residual 12 functional capacity to perform a full range of work at all exertional levels but with the following 13 nonexertional limitations: understand, remember, and apply short and simple instructions; 14 perform routine, predictable tasks; not in a fast-paced, production type environment; make

15 simple decisions; exposure to occasional, routine workplace changes; no interaction with the 16 general public; and occasional interaction with coworkers and supervisors, but not in a team 17 oriented environment. Tr. 622. The ALJ found plaintiff had no past relevant work, but as there 18 are jobs that exist in significant numbers in the national economy plaintiff could perform, she 19 was not disabled. Tr. 639-40. 20 DISCUSSION 21 The Court may reverse the ALJ’s decision only if it is not supported by substantial 22 evidence in the record as a whole or if the ALJ applied the wrong legal standard. Molina v. 23

1 20 C.F.R. §§ 404.1520, 416.920. 1 Astrue, 674 F.3d 1104, 1110 (9th Cir. 2012). The ALJ’s decision may not be reversed if the ALJ 2 committed harmless error. Id. at 1111. The Court may neither reweigh the evidence nor 3 substitute its judgment for that of the Commissioner. Thomas v. Barnhart, 278 F.3d 947, 954 4 (9th Cir. 2002). Where the evidence is susceptible to more than one rational interpretation, the

5 Court must uphold the Commissioner’s interpretation. Id. 6 A. Medical opinions 7 Plaintiff argues the ALJ erred in evaluating the medical opinions. Dkt. 16 at 3. For cases 8 filed before March 2017, as this one was, the ALJ should generally give more weight to the 9 opinion of a treating doctor than to a non-treating doctor, and more weight to the opinion of an 10 examining doctor than to a non-examining doctor. Lester v. Chater, 81 F.3d 821, 830 (9th Cir. 11 1996). Where not contradicted by another doctor, an ALJ may reject a treating or examining 12 doctor’s opinion only for “clear and convincing reasons.” Id. at 830-31. Where contradicted, an 13 ALJ may reject a treating or examining doctor’s opinion only by giving “specific and legitimate 14 reasons” that are supported by substantial evidence in the record. Id. at 830-31 (quoting Murray

15 v. Heckler, 722 F.2d 499, 502 (9th Cir. 1983)). An ALJ does this by setting out a detailed and 16 thorough summary of the facts and conflicting evidence, stating her interpretation of the facts 17 and evidence, and making findings. Magallanes v. Bowen, 881 F.2d 747, 751 (9th Cir. 1989). 18 The ALJ must do more than offer her conclusions; she must also explain why her interpretation, 19 rather than the treating doctor’s interpretation, is correct. Orn v. Astrue, 495 F.3d 625, 632 (9th 20 Cir. 2007) (citing Embrey v. Bowen, 849 F.2d 418, 421-22 (9th Cir. 1988)). 21 1. Dr. Bowes 22 Tasmyn Bowes, Psy.D., examined plaintiff in December 2015. Tr. 405-09. She opined 23 plaintiff had marked limitations in the ability to follow detailed instructions, perform activities 1 within a schedule, maintain regular attendance, be punctual within customary tolerances, 2 maintain appropriate behavior in a work setting, and complete a normal workday and work week 3 without interruptions from psychologically based symptoms, along with numerous additional 4 moderate limitations. Tr. 408. She opined that these limitations would last 6 to 12 months and

5 recommended psychotherapy, a psychiatric evaluation, and appropriate psychotropic 6 intervention. Tr. 409. 7 The ALJ gave this opinion limited weight. Tr. 633. The ALJ noted Dr. Bowes personally 8 examined plaintiff and the record supports limitations due to plaintiff’s mental health conditions, 9 but the ALJ also noted this examination occurred one month after plaintiff’s niece was taken 10 from her custody and it was thus reasonable that she had increased mental health symptoms so 11 soon after the traumatic occurrence. Id. The ALJ also found this examination was years prior to 12 plaintiff’s application date and Dr. Bowes did not review subsequent records, and that Dr. Bowes 13 noted numerous normal findings on mental status examination, which the ALJ found to be 14 inconsistent with marked limitations aside from social limitations and reports of panic and

15 agoraphobia. Id. The ALJ also noted Dr. Bowes was uncertain these limitations would last a year 16 and recommended evaluation and mental health treatment with plaintiff chose not to pursue. Id. 17 The ALJ found this opinion inconsistent with the overall record showing minimal and 18 conservative treatment for mental health conditions. Id. 19 Plaintiff argues the fact that Dr. Bowes’s opinion preceded the application date (by 14 20 months, not years, as plaintiff notes) does not make it irrelevant, as the opinion demonstrates 21 plaintiff’s longitudinal limitations. Dkt. 16 at 3. However, the ALJ could reasonably conclude 22 the opinion carried less weight because it predated the application date. See Carmickle v. 23 1 Comm’r Soc. Sec.

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

Related

Navarro-Chalan v. Ashcroft
359 F.3d 19 (First Circuit, 2004)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
Tommasetti v. Astrue
533 F.3d 1035 (Ninth Circuit, 2008)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Stubbs-Danielson v. Astrue
539 F.3d 1169 (Ninth Circuit, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Olson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/olson-v-commissioner-of-social-security-wawd-2024.