Piksa v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 5, 2024
Docket3:23-cv-05447
StatusUnknown

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

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 8 NICHOLAS P., 9 Plaintiff, Case No. C23-5447-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of his application for Supplemental Security Income. 15 Plaintiff contends the administrative law judge (“ALJ”) erred by: (1) failing to properly evaluate 16 Plaintiff’s testimony concerning his limitations; and (2) failing to properly evaluate Plaintiff’s 17 mental health impairments and credit them as severe at step two. (Dkt. # 7 at 1.) As discussed 18 below, the Court REVERSES the Commissioner’s final decision, and REMANDS this matter for 19 further administrative proceedings under sentence four of 42 U.S.C. § 405(g). 20 II. BACKGROUND 21 Plaintiff was born in 1985, has an associate’s degree in cybersecurity, and previously 22 worked as a glass shop glazer and a delivery driver. AR at 19, 32, 44-45, 237, 251. Plaintiff has 23 not engaged in substantial gainful activity since November 2019. Id. at 17. 1 On November 6, 2019, Plaintiff applied for benefits, alleging disability as of that date. 2 AR at 15. Plaintiff’s application was denied initially on November 30, 2020, and on 3 reconsideration on July 28, 2021, and Plaintiff requested a hearing. Id. After the ALJ conducted 4 a telephonic hearing on March 24, 2022, the ALJ issued a decision finding that Plaintiff was not

5 disabled and that he could perform work that existed in significant numbers in the national 6 economy. Id. at 15, 33-34. 7 As the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision is the 8 Commissioner’s final decision. AR at 1-3. Plaintiff appealed the final decision of the 9 Commissioner to this Court. (Dkt. # 1.) 10 III. LEGAL STANDARDS 11 Under 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of social 12 security benefits when the ALJ’s findings are based on legal error or not supported by substantial 13 evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 (9th Cir. 2005). As a 14 general principle, an ALJ’s error may be deemed harmless where it is “inconsequential to the

15 ultimate nondisability determination.” Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012) 16 (cited sources omitted). The Court looks to “the record as a whole to determine whether the error 17 alters the outcome of the case.” Id. 18 “Substantial evidence” is more than a scintilla, less than a preponderance, and is such 19 relevant evidence as a reasonable mind might accept as adequate to support a conclusion. 20 Richardson v. Perales, 402 U.S. 389, 401 (1971); Magallanes v. Bowen, 881 F.2d 747, 750 (9th 21 Cir. 1989). The ALJ is responsible for determining credibility, resolving conflicts in medical 22 testimony, and resolving any other ambiguities that might exist. Andrews v. Shalala, 53 F.3d 23 1035, 1039 (9th Cir. 1995). While the Court is required to examine the record as a whole, it may 1 neither reweigh the evidence nor substitute its judgment for that of the Commissioner. Thomas v. 2 Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When the evidence is susceptible to more than one 3 rational interpretation, it is the Commissioner’s conclusion that must be upheld. Id. 4 IV. DISCUSSION

5 A. The ALJ Erred in Discounting Plaintiff’s Testimony 6 Plaintiff first contends the ALJ erred in discounting his testimony. (Dkt. # 7 at 3-7.) 7 Plaintiff argues the ALJ failed to provide clear and convincing reasons for rejecting his 8 testimony that he needed to alternate between sitting and standing every 15 minutes and that he 9 required the ability to stretch for 20 minutes once to four times a day. (Id.) 10 Absent affirmative evidence showing the claimant is malingering, the ALJ must provide 11 “clear and convincing” reasons for rejecting a claimant’s testimony. Burrell v. Colvin, 775 F.3d 12 1133, 1136-37 (9th Cir. 2014) (citing Molina, 674 F.3d at 1112). The “clear and convincing” 13 standard does not ask “whether [the Court] is convinced, but instead whether the ALJ’s rationale 14 is clear enough that it has the power to convince.” See Smartt v. Kijakazi, 53 F.4th 489, 499 (9th

15 Cir. 2022). 16 At his hearing, Plaintiff testified he was unable to work because of chronic low back 17 pain, with radiating symptoms down his legs from his lumbar spine impairment, and due to 18 chronic fatigue and/or limited endurance that affected his functioning. AR at 54. Plaintiff 19 testified he could walk for only five minutes, or “half a block,” stand about 15 minutes before 20 needing to sit, and that he could sit one hour at a time. Id. at 56, 61. Plaintiff testified he could 21 repeat this for four to six hours a day, three days a week, but that afterwards, his back was done 22 and that he could not “do anything else the rest of the day that’s constructive.” Id. at 62. Plaintiff 23 testified that between one and four times a day, he took 20 minutes to stretch by sitting on a chair 1 and bending his body forward to touch his toes to ease his back pain. Id. at 57-58, 61. Plaintiff 2 testified he relied on a cane at times depending on his pain level, and that he had one to two 3 “worse” days per month, which would require him to sit or lie down for most of the day due to 4 his back pain. Id. at 56, 58-59.

5 In his decision, the ALJ found Plaintiff’s allegations were not sufficiently supported 6 because they were inconsistent with medical evidence in the record as well as Plaintiff’s 7 activities. AR at 21. With regard to Plaintiff’s lumbar spine condition, the ALJ determined the 8 medical evidence in the record did not establish the degree of physical limitation alleged. Id. at 9 26. The ALJ found the medical evidence demonstrated: (1) Plaintiff’s chronic back pain 10 improved with medication and medial branch blocks; (2) Plaintiff failed to follow through with 11 provider recommendations to have back surgery, suggesting his pain was not as debilitating as 12 alleged; and (3) that Plaintiff regularly ambulated with a normal gait, demonstrated full range of 13 motion of the spine and extremities, generally had full strength, sensation, and reflexes of the 14 extremities, and that his straight leg raise tests were generally negative. Id.

15 With regard to Plaintiff’s activities, the ALJ found the record suggested Plaintiff believed 16 himself capable of working despite his physical impairments. AR at 27. The ALJ found the 17 record demonstrated Plaintiff was able to obtain his associate’s degree in cybersecurity in June 18 2021 and that he applied for jobs throughout the relevant period, including a driving job. Id. The 19 ALJ also found that though Plaintiff indicated difficulties with daily functioning, the record 20 demonstrated Plaintiff was “quite active and functional.” Id.

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