Richardson v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedSeptember 27, 2021
Docket3:20-cv-08235
StatusUnknown

This text of Richardson v. Commissioner of Social Security Administration (Richardson 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
Richardson v. Commissioner of Social Security Administration, (D. Ariz. 2021).

Opinion

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

9 Kelly Richardson, No. CV-20-08235-PCT-GMS

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 16 At issue is the Commissioner of Social Security’s denial of Plaintiff Kelly 17 Richardson’s (“Plaintiff”) application for disability insurance benefits. Plaintiff filed a 18 Complaint (Doc. 1) with this Court seeking judicial review of that denial. For the following 19 reasons, the Court affirms the Administrative Law Judge’s (“ALJ”) decision (Doc. 23-3 at 20 32–41), as upheld by the Appeals Council, (Doc. 23-3 at 10–15.) 21 BACKGROUND 22 Plaintiff filed an Application for Disability Insurance benefits in January 2017 for a 23 period of disability beginning November 1, 2008. His claim was denied initially in March 24 2017 and upon reconsideration in June 2017. Plaintiff requested a hearing before an ALJ, 25 where he amended his onset date of disability to December 31, 2013. (Doc. 23-2 at 32). 26 On September 9, 2019, the ALJ rendered an unfavorable decision denying Plaintiff’s claim. 27 In May 2020, the Appeals Council denied Plaintiff’s request for review and adopted the 28 ALJ’s decision as the agency’s final decision. (Doc. 23-3 at 10). 1 Upon considering the medical records and opinions, the ALJ evaluated Plaintiff’s 2 disability based on the following severe impairments: morbid obesity, hypertension, and 3 hypothyroidism (Doc. 23-3 at 35). Ultimately, the ALJ concluded that Plaintiff was not 4 disabled from the alleged disability onset date through the date of the decision (Doc. 23-3 5 at 41). The ALJ found that Plaintiff could still perform sedentary work, including his past 6 relevant work as a user support agent (Doc. 23-3 at 40). Therefore, the ALJ denied his 7 claim. 8 DISCUSSION 9 I. Legal Standard 10 Because the severity of an impairment may be greater than what can be shown by 11 objective medical evidence alone, the ALJ considers a claimant’s subjective testimony 12 regarding pain and symptoms. 20 C.F.R. § 404.1529(c)(3); Burch v. Barnhart, 400 F.3d 13 676, 680 (9th Cir. 2005). The claimant, however, must still show objective medical 14 evidence of an underlying impairment that could reasonably be expected to produce the 15 pain or symptoms alleged. 42 U.S.C. § 423(d)(5)(A); 20 C.F.R. § 404.1529(a). Although 16 such evidence is required to show the existence of an underlying impairment, “the [ALJ] 17 may not discredit the claimant’s testimony as to subjective symptoms merely because they 18 are unsupported by objective evidence.” Berry v. Astrue, 622 F.3d 1228, 1234 (9th Cir. 19 2010). Nevertheless, the ALJ evaluates the testimony in relation to the objective medical 20 evidence and other evidence in determining the extent to which the pain or symptoms affect 21 her capacity to perform basic work activities. 20 C.F.R. § 404.1529(c)(4). 22 II. Analysis 23 At the administrative hearing, Plaintiff and his wife testified that due to his 24 disabilities, Plaintiff needs assistance taking care of himself in the bathroom, including for 25 bowel movements and showering. (Doc. 24 at 5.) Despite this testimony, the ALJ opined 26 that Plaintiff’s “subjective complaints were not fully consistent with the evidence[,] and 27 the objective medical evidence [did] not support the alleged severity of symptoms.” (Doc. 28 23-3 at 39.) Plaintiff argues that (1) the ALJ failed to specifically reject his testimony about 1 needing assistance in the bathroom; and (2) even if the ALJ did specifically reject this 2 testimony, she failed to provide adequate reasoning for doing so.1 3 A. The ALJ Specifically Rejected Plaintiff’s Testimony 4 Plaintiff first argues that the ALJ erred by not specifically rejecting Plaintiff’s 5 testimony about needing assistance in the bathroom. General findings pertaining to a 6 claimant’s credibility are not sufficient to support rejecting his testimony. Lester v. Chater, 7 81 F.3d 821, 834 (9th Cir. 1995). Rather, “the ALJ must specifically identify the testimony 8 she or he finds not to be credible and must explain what evidence undermines the 9 testimony.” Holohan v. Massanari, 246 F.3d 1195, 1208 (9th Cir. 2001). In doing so, the 10 ALJ need not engage in “extensive” analysis but should, at the very least “provide some 11 reasoning in order for [a reviewing court] to meaningfully determine whether [the ALJ’s] 12 conclusions were supported by substantial evidence.” Brown-Hunter v. Colvin, 806 F.3d 13 487, 495 (9th Cir. 2015). 14 Here, the ALJ’s decision begins by reviewing Plaintiff’s and his wife’s testimony— 15 which included the testimony at issue—and by concluding that Plaintiff’s statements 16 “concerning the intensity, persistence[,] and limiting effects of these symptoms are not 17 entirely consistent with the medical evidence.” (Doc. 23-3 at 37.) The ALJ then 18 specifically rejects Plaintiff’s testimony regarding the “severity of symptoms” caused by 19 his “morbid obesity.” (Doc. 23-3 at 37.) That sentence is followed by two paragraphs of 20 support. (Doc. 23-3 at 38.) The statement recounting Plaintiff’s issues in the bathroom— 21 which is closely followed by a rejection of his symptom testimony altogether—is 22 sufficiently specific. The ALJ need not provide “extensive” analysis—only enough for a 23 court to discern what testimony is being rejected. Clearly, a recounting of testimony 24 followed by a rejection of that testimony is sufficient to meet this standard. This is 25 especially true, where, as here, there is no evidence that Plaintiff discussed this specific

26 1 Although Plaintiff did not raise these issues during the administrative hearing, his failure to do so does not preclude him from raising them on appeal. Milne v. Berryhill, No. 5:17– 27 cv–01042–SHK, 2018 WL 3197749, at *5–6 (June 27, 2018 C.D. Cal.) (reviewing Ninth Circuit precedent regarding waiver); Shaibi v. Berryhill, 883 F.3d 1102, 1109 (9th Cir. 28 2017) (narrowly holding that forfeiture applies when claimants fail to challenge vocational experts’ job estimates during the administrative hearing). 1 problem as causing difficulties with any of his medical providers prior to the date he was 2 last insured. (Doc. 23-3 at 39.) The ALJ, therefore, sufficiently rejected Plaintiff’s specific 3 testimony relating to the hygiene difficulties caused by his obesity. 4 B. Specific, Clear, and Convincing Reasons 5 Plaintiff next argues that the ALJ did not provide “specific, clear, and convincing 6 reasons” to reject his testimony. Unless there is evidence of malingering by the claimant, 7 the ALJ may only reject symptom testimony for reasons that are specific, clear, and 8 convincing. Burch, 400 F.3d at 680. In evaluating the credibility of a claimant’s testimony, 9 the ALJ may consider the claimant’s “reputation for truthfulness, inconsistencies either in 10 his testimony or between his testimony and his conduct, his daily activities, his work 11 record, and testimony from physicians and third parties concerning the nature, severity, 12 and effect of the symptoms of which he complains.” Light v. Soc.

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Related

Berry v. Astrue
622 F.3d 1228 (Ninth Circuit, 2010)
DeGrandis v. Children's Hospital Boston
806 F.3d 13 (First Circuit, 2015)
Lester v. Chater
81 F.3d 821 (Ninth Circuit, 1995)
Nevada v. Department of Energy
400 F.3d 9 (D.C. Circuit, 2005)
Shaibi v. Berryhill
883 F.3d 1102 (Ninth Circuit, 2017)

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Richardson v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richardson-v-commissioner-of-social-security-administration-azd-2021.