Robertson v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedMay 7, 2021
Docket3:20-cv-05154
StatusUnknown

This text of Robertson v. Commissioner of Social Security (Robertson 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
Robertson v. Commissioner of Social Security, (W.D. Wash. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 DEREK R., Case No. 3:20-cv-05154-TLF 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, 10 Defendant. 11 12 Plaintiff has brought this matter for judicial review of defendant’s denial of his 13 applications for disability insurance (DIB) and supplemental security income (SSI) 14 benefits. 15 The parties have consented to have this matter heard by the undersigned 16 Magistrate Judge. 28 U.S.C. § 636(c); Federal Rule of Civil Procedure 73; Local Rule 17 MJR 13. 18 I. ISSUES FOR REVIEW 19 A. Did the Administrative Law Judge (“ALJ”) err in evaluating Plaintiff’s 20 subjective symptom testimony? 21 B. Did the ALJ err in assessing medical opinion evidence? 22 C. Did the ALJ err in assessing lay witness testimony? 23 D. Was the Plaintiff’s residual functional capacity (“RFC”) determination 24 supported by substantial evidence? 1 II. BACKGROUND 2 On October 2016, Plaintiff filed applications for DIB and SSI, alleging in both 3 applications a disability onset date of December 31, 2013. Administrative Record (AR) 4 351–52, 359. Plaintiff’s applications for DIB and SSI were denied upon official review

5 and upon reconsideration. AR 201–02, 227–28. A hearing was held before ALJ Paul 6 Gaughen on September 18, 2018. AR 160–89. On November 29, 2018, the ALJ issued 7 a decision finding that Plaintiff was not disabled. AR 28–51. On December 17, 2019, the 8 Social Security Appeals Council denied Plaintiff’s request for review. AR 1–7. 9 Plaintiff seeks judicial review of the ALJ’s November 29, 2018 decision. Dkt. 4. 10 III. STANDARD OF REVIEW 11 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s 12 denial of Social Security benefits if the ALJ’s findings are based on legal error or not 13 supported by substantial evidence in the record as a whole. Revels v. Berryhill, 874 14 F.3d 648, 654 (9th Cir. 2017). Substantial evidence is “‘such relevant evidence as a

15 reasonable mind might accept as adequate to support a conclusion.’” Biestek v. 16 Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations omitted). 17 IV. DISCUSSION 18 In this case, the ALJ found that Plaintiff had the severe, medically determinable 19 impairments of affective anxiety-related post-traumatic stress disorder (“PTSD”), 20 substance addiction disorders, and a severe musculoskeletal impairment to his right 21 hand. AR 34. Based on the limitations stemming from these impairments, the ALJ found 22 that Plaintiff could perform a reduced range of light work. AR 37. Relying on vocational 23 expert (“VE”) testimony, the ALJ found at step four that Plaintiff could not perform his

24 past relevant work, but could perform other light, unskilled jobs at step five of the 1 sequential evaluation; therefore, the ALJ determined at step five that Plaintiff was not 2 disabled. AR 44. 3 A. Whether the ALJ Erred in Assessing Plaintiff’s Subjective Symptom 4 Testimony

5 Plaintiff avers that the ALJ’s adverse credibility finding as to his own symptom 6 testimony was not supported by adequate reasoning. Dkt. 18, pp. 12–17. 7 In weighing a plaintiff’s testimony, an ALJ must use a two-step process. Trevizo 8 v. Berryhill, 871 F.3d 664, 678 (9th Cir. 2017). First, the ALJ must determine whether 9 there is objective medical evidence of an underlying impairment that could reasonably 10 be expected to produce some degree of the alleged symptoms. Ghanim v. Colvin, 763 11 F.3d 1154, 1163 (9th Cir. 2014). If the first step is satisfied, and provided there is no 12 evidence of malingering, the second step allows the ALJ to reject the claimant’s 13 testimony of the severity of symptoms if the ALJ can provide specific findings and clear 14 and convincing reasons for rejecting the claimant’s testimony. Id.

15 In addition to testifying at the hearing, Plaintiff submitted function reports in 16 November 2016 and January 2017. See AR 405–12, 432–39. In each report, he 17 described “up and down” shifts in his mood from one day to the next and stated that, on 18 some days, he was so depressed that he did not want to leave his bed, comparing this 19 experience to “hibernating.” AR 405, 412, 432. He also stated that he had difficulty in 20 dealing with authority figures and felt “just negative towards people” in general, suffered 21 from a stutter and frequent forgetfulness, and struggled to summon the necessary 22 concentration or motivation to complete tasks. AR 410. 23

24 1 The ALJ found that Plaintiff’s symptoms were less severe than he alleged, 2 reasoning that (1) his statements were inconsistent with his activities of daily living, (2) 3 Plaintiff sought only conservative treatment for these symptoms, and treatment 4 mitigated his symptoms significantly, and (3) the symptoms alleged were inconsistent

5 with objective medical evidence. AR 36–37. 6 With respect to the ALJ’s first reason, a claimant’s participation in everyday 7 activities, indicating capacities that are transferable to a work setting, may constitute 8 grounds for an adverse credibility determination. Orn v. Astrue, 495 F.3d 625, 630 (9th 9 Cir. 2007) (emphasis added). Yet, disability claimants should not be penalized for 10 attempting to lead normal lives in the face of their limitations. See Reddick v. Chater, 11 157 F.3d 715, 722 (9th Cir. 1998) (citing Cooper v. Bowen, 815 F.2d 557, 561 (9th Cir. 12 1987) (claimant need not “vegetate in a dark room” in order to be deemed eligible for 13 benefits)). 14 Here, the activities listed by the ALJ included Plaintiff’s participation in mixed

15 martial arts (“MMA”) cage fighting and weightlifting, part-time work, and attendance at 16 Alcoholics Anonymous (“AA”) and Narcotics Anonymous (“NA”) meetings. First, the 17 ALJ’s citations to the record do not indicate either the frequency or intensity with which 18 Plaintiff engaged in MMA cage fights or weightlifting. See AR 514 (documenting hand 19 injury from MMA); 560 (stating Plaintiff had “been lifting more weights for exercise” with 20 no indication of how frequently this took place). At the hearing, Plaintiff stated that he 21 had taken up MMA at the encouragement of his family as a way to mitigate his anger 22 issues, and that he broke his left hand while fighting, forcing him to quit altogether. AR 23 170–71.

24 1 The ALJ’s citations to portions of the record documenting Plaintiff’s work 2 activities, similarly, do not support a finding that Plaintiff was able to adhere to the rigors 3 of a full-time job. AR 41 (citing AR 518, 554, 557). Indeed, the ALJ’s last citation on this 4 topic is to a medical record indicating Plaintiff had to miss work due to severe pain. AR

5 564. The ALJ relied on Plaintiff’s work activity to show he was not limited by his hand 6 injury, but there is not any indication in these records as to how frequently he was 7 required to use his right hand; indeed, at the hearing, Plaintiff testified to a work-related 8 injury to his right hand in 2016. AR 41; see also AR 176. Finally, the record does not 9 disclose the frequency with which Plaintiff attended AA or NA meetings or assumed any 10 volunteer duties in these organizations. Without more, Plaintiff’s activities are not a 11 clear and convincing reason supporting an adverse credibility determination. See Fair v.

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Bluebook (online)
Robertson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robertson-v-commissioner-of-social-security-wawd-2021.