Rodenhauser v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedOctober 9, 2024
Docket2:23-cv-02011
StatusUnknown

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

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 JESSICA R., Case No. 23-cv-02011-TLF 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S ACTING COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, 10 Defendant. 11 This Court has jurisdiction pursuant to 28 U.S.C. § 636(c), Fed. R. Civ. P. 73 and 12 Local Magistrate Judge Rule (MJR) 13. See also Consent to Proceed Before a United 13 States Magistrate Judge, Dkt. 2. This matter has been fully briefed. See Dkts. 10, 12, 14 13. 15 The Court finds the ALJ harmfully erred in deciding that Plaintiff was not 16 disabled, and accordingly REVERSES AND REMANDS the Commissioner’s final 17 decision in this matter. 18 PROCEDURAL HISTORY 19 Plaintiff filed an application for disability benefits under Title II on September 7, 20 2020. See Administrative Record (“AR”) 115. She alleges disability beginning on August 21 12, 2020. AR 115. The date last insured is December 31, 2025. AR 115 The claim was 22 denied initially on May 7, 2019, and upon reconsideration on September 21, 2021. AR 23 24 1 115. Plaintiff’s requested hearing was held before ALJ Laura Valente. AR 115. The ALJ 2 denied Plaintiff’s claim by written decision on January 31, 2023. AR 115-126. 3 After the Appeals Council denied Plaintiff’s request for review, she sought judicial 4 review of the ALJ’s decision in this Court.

5 BACKGROUND 6 The ALJ’s decision found Plaintiff suffers from the severe impairments of 7 Guillain-Barre syndrome (GBS), obesity, bulimia, anxiety disorder, and depressive 8 disorder. AR 117 The ALJ found Plaintiff was not disabled because she had the 9 following residual functional capacity (“RFC”): 10 perform light work as defined in 20 CFR 404.1567(b) except she can sit 6 hours in an 8-hour workday; she can stand and or walk 6 hours combined 11 in a n 8-hour workday; she can work superficially and occasionally with general public; she can work in same room with coworkers but not in 12 coordination with them; she can adapt to simple, occasional and predictable routine workplace changes; and she must avoid hazards. 13 AR 119. 14 DISCUSSION 15 Under 42 U.S.C. § 405(g), this Court may set aside the Commissioner's denial of 16 social security benefits when the ALJ's findings are based on legal error or not 17 supported by substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 18 F.3d 1211, 1214 (9th Cir. 2005). As a general principle, an ALJ's error may be deemed 19 harmless where it is “inconsequential to the ultimate nondisability determination.” Molina 20 v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012) (cited sources omitted). The Court looks 21 to “the record as a whole to determine whether the error alters the outcome of the 22 case.” Id. 23 24 1 “Substantial evidence” is more than a scintilla, less than a preponderance, and is 2 such relevant evidence as a reasonable mind might accept as adequate to support a 3 conclusion. Richardson v. Perales, 402 U.S. 389, 401 (1971); Magallanes v. Bowen, 4 881 F.2d 747, 750 (9th Cir. 1989). The ALJ is responsible for determining credibility,

5 resolving conflicts in medical testimony, and resolving any other ambiguities that might 6 exist. Andrews v. Shalala, 53 F.3d 1035, 1039 (9th Cir. 1995). While the Court is 7 required to examine the record as a whole, it may neither reweigh the evidence nor 8 substitute its judgment for that of the Commissioner. Thomas v. Barnhart, 278 F.3d 947, 9 954 (9th Cir. 2002). When the evidence is susceptible to more than one rational 10 interpretation, it is the Commissioner's conclusion that must be upheld. Id. 11 Plaintiff’s Opening Brief raises the following issues: 12 1. The ALJ discounted Plaintiff’s testimony without legally supported reasons and 13 without substantial evidence to justify rejecting her statements. 14 2. The ALJ’s decision regarding the medical opinions is not supported by

15 substantial evidence. 16 3. The ALJ failed to provide germane reasons supported by substantial evidence in 17 assess the lay witness opinions. 18 A. Plaintiff’s Statements Regarding Symptoms and Limitations

19 Plaintiff assigns error to the ALJ’s evaluation of her statements about her experience 20 of symptoms and work-related limitations. In weighing a plaintiff's testimony, an ALJ 21 must use a two-step process. Trevizo v. Berryhill, 871 F.3d 664, 678 (9th Cir. 217). 22 First, the ALJ must determine whether there is objective medical evidence of an 23 underlying impairment that could reasonably be expected to produce some degree of 24 1 the alleged symptoms. Ghanim v. Colvin, 763 F.3d 1154, 1163 (9th Cir. 2014). If the 2 first step is satisfied, and provided there is no evidence of malingering, the second step 3 allows the ALJ to reject the claimant's testimony of the severity of symptoms if the ALJ 4 provides specific findings and clear and convincing reasons for rejecting the claimant's

5 testimony. Id. See Verduzco v. Apfel, 188 F.3d 1087, 1090 (9th Cir. 1999) (inconsistent 6 testimony about symptoms is clear and convincing reason to discount subjective 7 allegations). The ALJ is required to state what testimony they determined to be not 8 credible and point to the evidence that undermines the plaintiff's credibility. Dodrill v. 9 Shalala, 12 F.3d 915, 918 (9th Cir. 1993). 10 In this case, the ALJ’s decision found Plaintiff’s physical complaints were out of 11 proportion to the objective medical evidence of record. AR 120. “Contradiction with the 12 medical record is a sufficient basis for rejecting the claimant’s subjective testimony.” 13 Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155, 1161 (9th Cir. 2008) (citing 14 Johnson v. Shalala, 60 F.3d 1428, 1434 (9th Cir.1995)).

15 The ALJ noted that, during a visit in October 2020 with Dr. Matthew Preston, the 16 Plaintiff reported she was feeling “great.” AR 121, 843. This was after Plaintiff was 17 recently discharged from the hospital during which she had extremity pain, paresthesia 18 and facial droop. AR 836-837. During this visit, Plaintiff still noted persistent numbness, 19 tingling, and occasional lightheadedness, and Dr. Preston found abnormal findings in 20 the cranial nerves, strength, reflexes, and heel and tandem walking. AR 844-45. 21 The ALJ also noted Plaintiff had been without her walker since her discharge 22 from rehabilitation, was taking care of her child and puppy, reportedly going camping 23 with her son, and had vacationed in Spain. An ALJ may discount a claimant's testimony

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
Luther v. Countrywide Home Loans Servicing LP
533 F.3d 1031 (Ninth Circuit, 2008)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Jasim Ghanim v. Carolyn W. Colvin
763 F.3d 1154 (Ninth Circuit, 2014)
Leopoldo Leon v. Nancy Berryhill
880 F.3d 1041 (Ninth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Rodenhauser v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodenhauser-v-commissioner-of-social-security-wawd-2024.