Richter v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedApril 14, 2025
Docket2:24-cv-01457
StatusUnknown

This text of Richter v. Commissioner of Social Security (Richter 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
Richter v. Commissioner of Social Security, (W.D. Wash. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA/ SEATTLE 6 JEFFREY R. , Case No. 2:24-cv-01457-TLF 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S ACTING COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, 10 Defendant. 11 12 Plaintiff filed this action pursuant to 42 U.S.C. § 405(g) for judicial review of 13 defendant’s denial of plaintiff’s application for supplemental security income (“SSI”) and 14 disability insurance benefits (“DIB”). Pursuant to 28 U.S.C. § 636(c), Federal Rule of 15 Civil Procedure 73, and Local Rule MJR 13, the parties have consented to have this 16 matter heard by the undersigned Magistrate Judge. Dkt. 2. Plaintiff challenges the ALJ’s 17 decision finding that plaintiff was not disabled. Dkt. 1, Complaint. 18 BACKGROUND 19 Plaintiff filed his applications for Title II and Title XVI benefits on April 10, 2021. 20 AR 21. The claims were denied initially on December 20, 2021, and upon 21 reconsideration on June 2, 2022. Id. The date of alleged onset was March 30, 2021, 22 and the date last insured will be December 31, 2025. AR 21-22. 23 Plaintiff appealed and ALJ Laureen Penn held a hearing on October 4, 2023; the 24 ALJ issued a decision on October 17, 2023 finding the plaintiff not disabled. AR 21-32. 1 The ALJ found that plaintiff had the following severe impairments: ankylosing spondylitis 2 and sacroiliitis. AR 24. The ALJ found that plaintiff has the residual functional capacity 3 (RFC): 4 to perform light work as defined in 20 CFR 404.1567(b) and 416.967(b) except he can lift and carry twenty pounds occasionally, ten pounds 5 frequently. He can stand and walk for six hours and can sit for six hours. He can occasionally climb stairs and ramps, balance, stoop, crouch, and 6 kneel but cannot crawl or climb ladders, ropes, or scaffolds. He cannot have concentrated exposure to extreme cold, extreme heat, vibration, and 7 hazards, including unprotected heights and moving machinery. He would miss one day of work per month. 8 AR 26. Based on hypotheticals posed to the Vocational Expert (VE) at the hearing, the 9 ALJ concluded plaintiff could not perform his past work but could work, instead, as a 10 marker, router, taproom attendant, routing clerk, mail clerk, document preparer, election 11 clerk, call out operator, or telephone quotation clerk. AR 65-68. 12 STANDARD 13 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner's 14 denial of Social Security benefits if the ALJ's findings are based on legal error or not 15 supported by substantial evidence in the record as a whole. Revels v. Berryhill, 874 16 F.3d 648, 654 (9th Cir. 2017) (internal citations omitted). Substantial evidence is “‘such 17 relevant evidence as a reasonable mind might accept as adequate to support a 18 conclusion.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations 19 omitted). The Court must consider the administrative record as a whole. Garrison v. 20 Colvin, 759 F.3d 995, 1009 (9th Cir. 2014). The Court also must weigh both the 21 evidence that supports and evidence that does not support the ALJ’s conclusion. Id. 22 The Court may not affirm the decision of the ALJ for a reason on which the ALJ did not 23 rely. Id. Rather, only the reasons identified by the ALJ are considered in the scope of 24 1 the Court’s review. Id. 2 Plaintiff argues that the ALJ committed reversible error for the following reasons: 3 1) the ALJ failed to provide clear and convincing reasons supported by substantial 4 evidence for rejecting plaintiff’s testimony about his symptoms and functional limitations

5 related to his ankylosing spondylitis and sacroiliitis; and 2) the ALJ erred by finding at 6 step five that plaintiff can perform other work. Dkt. 11 at 1. 7 DISCUSSION 8 I. Plaintiff’s Statements About Symptoms and Limitations 9 Plaintiff argues the ALJ did not provide specific, clear and convincing reasons 10 supported by substantial evidence for rejecting plaintiff’s testimony about his symptoms 11 and functional limitations. Dkt. 11 at 3. Plaintiff further argues that the ALJ’s decision 12 does not explain what specific portions of plaintiff’s testimony lacked credibility and 13 failed to link reasons to specific evidence that undermined plaintiff’s testimony. Id. 14 To assess the credibility of a claimant’s testimony on subjective symptoms and

15 limitations, the ALJ must engage in a two-step analysis. Social Security Ruling 16-3p, 16 Titles II & XVI: Evaluation of Symptoms in Disability Claims, 2016 WL 1119029 (S.S.A. 17 Mar. 16, 2016). First, the ALJ “must consider whether there is an underlying medically 18 determinable physical or mental impairment(s) that could reasonably be expected to 19 produce an individual’s symptoms. Where the plaintiff has presented objective medical 20 evidence to meet the first step and there is no affirmative evidence of malingering, the 21 ALJ can only reject plaintiff’s testimony by providing specific, clear and convincing 22 reasons supported by substantial evidence.” Ghanim v. Colvin, 763 F.3d 1154, 1163 23 (9th Cir. 2014) (citing Lingenfelter v. Astrue, 504 F.3d 1028, 1036 (9th Cir. 2007)).

24 1 Plaintiff testified that he can probably lift at most 30 pounds and walk as far as a 2 quarter of a mile before having to stop and rest. AR 329. He stated that he cannot 3 stand, squat, kneel, sit, or bend for long periods of time. Id. In a function report he 4 stated, “I struggle to get even the most mundane household tasks accomplished on

5 many days” and that “it is a struggle for me to get up, get moving, and do something as 6 simple as the dishes and regular chores around my home.” AR 290, 297. 7 Plaintiff stated that he prepares simple foods (sandwiches, cereal, fruit) and 8 grocery shops every one to two weeks. AR 355. He tries to sweep the house when he 9 feels up to it, and folds laundry sometimes. Id. He stated, “when I do start a task, I go 10 slow so I don’t overdo it” and that there are many days he cannot do any tasks because 11 of pain and mobility problems. AR 324. 12 At the hearing, plaintiff testified he always wakes up with stiffness that takes 13 hours to go away, which affects his ability to do basic things such as dress himself. AR 14 47. He has to sleep in a recliner to take the pressure off his hips; laying down in a bed is

15 too painful. AR 45-46. He finds it difficult to get up off the couch without his cane or 16 assistance from another person. AR 52. Family and friends help with basic outdoor 17 chores because it is hard for him to go outside every day. AR 53. He uses his cane 18 probably 50% of the time and has fallen. AR 57. 19 a. Objective Medical Evidence 20 The ALJ summarized much of the medical evidence and then stated that while 21 the evidence supports that plaintiff’s conditions create exertional, postural, and 22 environmental limitations, these limitations are not as severe as alleged by the plaintiff. 23 AR 27-30. She stated that despite his complaints, “his symptoms generally remained

24 1 stable with ongoing conservative treatment, his examiners frequently did not note the 2 use of any assistive devices, and later medical imaging showed no evidence of 3 ankylosis.” AR 30.

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Bluebook (online)
Richter v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richter-v-commissioner-of-social-security-wawd-2025.