Oswalt v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedSeptember 12, 2022
Docket4:20-cv-00556
StatusUnknown

This text of Oswalt v. Commissioner of Social Security Administration (Oswalt v. Commissioner of Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oswalt v. Commissioner of Social Security Administration, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Jennifer Oswalt, No. CV-20-00556-TUC-JGZ

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 On June 30, 2022, Magistrate Judge D. Thomas Ferraro issued a Report and 16 Recommendation (R&R) recommending that the Court vacate the Commissioner’s final 17 decision denying Plaintiff Jennifer Oswalt’s application for Social Security disability 18 benefits and remand the case for further administrative proceedings. (Doc. 25.) On July 13, 19 2022, the Commissioner filed an Objection to the Report and Recommendation. (Doc. 27.) 20 Oswalt timely responded. (Doc. 28.) After reviewing the Report and Recommendation and 21 considering the arguments raised in the Commissioner’s Objection, the Court will overrule 22 the Objection and adopt Judge Ferraro’s Recommendation. 23 STANDARD OF REVIEW 24 When reviewing a Magistrate Judge’s R&R, this Court “may accept, reject, or 25 modify, in whole or in part, the findings or recommendations made by the magistrate 26 judge.” 28 U.S.C. § 636(b)(1). “[T]he district judge must review the magistrate judge’s 27 findings and recommendations de novo if objection is made, but not otherwise.” United 28 States v. Reyna-Tapia, 328 F.3d 1114, 1121 (9th Cir. 2003) (en banc). District courts are 1 not required to conduct “any review at all . . . of any issue that is not the subject of an 2 objection.” Thomas v. Arn, 474 U.S. 140, 149 (1985); see also 28 U.S.C. § 636(b)(1); Fed. 3 R. Civ. P. 72. Further, a party is not entitled as of right to de novo review of evidence or 4 arguments which are raised for the first time in an objection to the R&R, and the Court’s 5 decision to consider newly-raised arguments is discretionary. Brown v. Roe, 279 F.3d 742, 6 744 (9th Cir. 2002); United States v. Howell, 231 F.3d 615, 621–22 (9th Cir. 2000). 7 BACKGROUND 8 The parties do not object to the Magistrate Judge’s summary of the factual and 9 procedural background. (Doc. 25 at 1–6.) Therefore, the Court does not restate the facts 10 here and instead includes the relevant facts in its discussion of the issues presented. 11 DISCUSSION 12 The Commissioner objects to the Magistrate Judge’s conclusions that the 13 Administrative Law Judge (ALJ) erred in (1) evaluating the objective medical evidence 14 concerning Oswalt’s narcolepsy and (2) discounting Oswalt’s subjective complaints about 15 her narcolepsy-related symptoms. (Doc. 27.) The Commissioner argues that the ALJ did 16 not err in evaluating the objective medical evidence and reasonably found that Oswalt was 17 less limited from narcolepsy than she alleged. (Id. at 3.) The Commissioner asserts that the 18 ALJ did not err in discounting Oswalt’s symptom testimony because it was inconsistent 19 with several objective factors. (Id.) The Court will address the Objections in turn.1 20 I. ALJ’s Analysis of Objective Medical Evidence 21 The Magistrate Judge concluded that the ALJ erred in her analysis of the objective 22 medical evidence when she reasoned that Oswalt’s normal MRI, EEGs and alertness at 23 examinations were inconsistent with the alleged severity of Oswalt’s narcolepsy. (Doc. 25 24 at 9.) The R&R notes that the ALJ’s analysis was directly contrary to the Evaluation of 25 Narcolepsy guidance provided in Program Operations Manual System (POMS) DI 26 24580.005, without any explanation as to the difference.2 (Id.) The guidance provides that: 27 1 The Court acknowledges the appropriate standard of review of the Commissioner’s final 28 decision is that set forth in the R&R. (Doc. 25 at 6–7.) 2 POMS do not create a judicially enforced duty on either courts or ALJs; they are agency 1 “There are no physical abnormalities in narcolepsy, and with the exception of sleep studies, 2 laboratory studies will be normal. . . . Once awakened, the narcoleptic patient is alert. . . . 3 It is not necessary to obtain an electroencephalogram (EEG) in narcolepsy cases. A routine 4 EEG is usually normal.” POMS DI 24580.005(B)–(C). 5 The Commissioner argues that “no error under the POMS occurred” because the 6 guidance “simply explains how objective medical findings typically appear in narcolepsy 7 cases,” and other factors are relevant to the determination of severity. (Doc. 27 at 2.) The 8 Commissioner asserts that the ALJ agreed that narcolepsy was one of Oswalt’s medically 9 determinable severe impairments, then addressed the impact of narcolepsy based on the 10 sum total of the evidence, reasonably finding Oswalt less limited from narcolepsy than 11 alleged. (Id. at 2–3.) 12 The Commissioner’s argument is unavailing. While correct that the POMS explains 13 how objective medical findings typically appear, the Commissioner does not address the 14 fact that the ALJ relied on test results consistent with narcolepsy as evidence that Oswalt’s 15 narcolepsy was not disabling. The ALJ stated “despite having normal EEG studies, the 16 claimant continued to endorse losing blocks of time and a decline in memory. . . . Similar 17 to previous diagnostic tests, the MRI came back normal. . . . This undermines the 18 persuasiveness of claimant’s subjective allegations.” (AR 21, emphasis added.)3 Normal 19 MRI and EEG results are expected in a patient with narcolepsy, and the ALJ provided no 20 justification for departing from the POMS guidance to conclude that Oswalt’s test results 21 undermined her allegations. Additionally, the Commissioner fails to address the fact that 22 one of the “normal” EEGs that the ALJ relied on showed two “brief jerking movements,” 23 consistent with hypnopompic jerk or sleep related movements. (AR 21, 855–56.) 24 Further the ALJ reasoned that Oswalt’s reported fatigue and excessive daytime 25 somnolence were “inconsistent with objective findings where treating physicians and 26 interpretations entitled to respect when they have the power to persuade. Lockwood v. 27 Comm’r Social Sec. Admin., 616 F.3d 1068, 1073 (9th Cir. 2010). 3 The Administrative Record (AR) is found at Doc. 18. The Court cites to documents 28 contained in the Record using the bates numbers found on the bottom right corner of the documents. 1 medical staff have routinely described the claimant’s mentation as alert and oriented during 2 examinations.” (AR 21.) The Commissioner argues that “the ALJ could reasonably 3 consider the objective findings of alertness, orientation, and good attention/concentration” 4 as a factor inconsistent with the alleged severity of Oswalt’s narcolepsy. However, it is not 5 reasonable to conclude that a patient’s alertness during a brief doctor’s appointment or 6 exam is evidence that narcolepsy is not present or severe, especially when the POMS 7 guidance explains that an awake narcoleptic patient will present as alert. Again, the ALJ 8 provided no justification for interpreting the objective medical evidence contrary to the 9 POMS guidance. 10 In sum, the Court agrees with the Magistrate Judge that the ALJ erred in concluding 11 that Oswalt’s MRI, EEGs, and alertness at exams undermined the severity of her 12 narcolepsy. Thus, the ALJs factual findings interpreting the objective medical evidence are 13 not supported by substantial evidence.

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Oswalt v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oswalt-v-commissioner-of-social-security-administration-azd-2022.