Roush v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedMarch 10, 2021
Docket3:20-cv-05705
StatusUnknown

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

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 THERESA R., 8 Plaintiff, Case No. C20-5705 RAJ 9 v. ORDER REVERSING AND 10 REMANDING DEFENDANT’S 11 COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS SECURITY, 12 Defendant. 13 Plaintiff seeks review of the denial of her applications for Supplemental Security 14 Income and Disability Insurance Benefits. Plaintiff contends the ALJ erred by rejecting 15 her symptom testimony and the opinions of treating provider Karl Sembroski, PA. Dkt. 16 12, p. 1. As discussed below, the Court REVERSES the Commissioner’s final decision 17 and REMANDS the matter for further administrative proceedings under sentence four of 18 19 42 U.S.C. § 405(g). 20 BACKGROUND 21 Plaintiff is 51 years old, has at least a high school education, and has worked as a 22 hairstylist. Admin. Record (“AR”) (Dkt. 10) 26–27, 94, 236. On June 15, 2017, Plaintiff 23 applied for benefits, later alleging an amended disability onset date of August 28, 2017. 1 AR 94–95, 196–201, 211–19. Plaintiff’s applications were denied initially and on 2 reconsideration. AR 93–128. 3 ALJ Gerald Hill conducted a hearing on May 21, 2019, after which he issued a 4 decision finding Plaintiff not disabled. AR 15–28, 35–66. In relevant part, ALJ Hill 5 found Plaintiff had severe impairments of degenerative disc disease, fibromyalgia, 6 chronic pain syndrome, migraines, depression, and obesity. AR 18. The ALJ found 7 Plaintiff had the residual functional capacity (“RFC”) to perform light work with 8 additional exertional, postural, manipulative, and environmental restrictions. See AR 21. 9 The ALJ found plaintiff had additional cognitive and social limitations. See id. 10 The Appeals Council denied Plaintiff’s request for review, making the ALJ’s 11 12 decision the Commissioner’s final decision. AR 1–3. 13 DISCUSSION 14 The Court may set aside the Commissioner’s denial of Social Security benefits 15 only if the ALJ’s decision is based on legal error or not supported by substantial evidence 16 in the record as a whole. Ford v. Saul, 950 F.3d 1141, 1153–54 (9th Cir. 2020). 17 A. Plaintiff’s Symptom Testimony 18 Plaintiff contends the ALJ erred by rejecting her testimony regarding the severity 19 of symptoms from her physical and mental impairments.1 Dkt. 12, pp. 2–5. Plaintiff 20 testified she gets migraines three to four times a month, and they can last from 24 hours 21 22 1 Plaintiff inexplicably contends the ALJ failed to give “germane” reasons for rejecting her 23 symptom testimony. Dkt. 21, p. 2. An ALJ is required to meet a higher standard than this, and counsel risks prejudicing his own client by suggesting a lower standard. 1 up to three days. See AR 41–42, 250, 280. She testified she has flares of pain that can 2 last 24 hours, and it will be two to three days before she can function “a little bit better.” 3 AR 45. She testified she has carpal tunnel syndrome in her right hand. See AR 45, 242. 4 She testified she has limited use of her hands. AR 295. Plaintiff testified she has left 5 shoulder impingement. AR 45–46. She testified she can sit for a half hour at a time. See 6 AR 47, 242, 247, 300. She testified she can stand and/or walk for one to two hours at a 7 time. See AR 47, 242, 247, 300. She testified she has to lie down for a half hour to an 8 hour two or three times a day. AR 47. On a bad day, she will lie down for seven hours in 9 an eight-hour period. AR 49. Plaintiff testified she can lift 15 pounds on a good day, and 10 less on a bad day. See AR 48, 247, 300. She testified about four out of seven days a 11 12 week are bad days. AR 49–50. She testified at times her pain gets bad enough to affect 13 her ability to focus and concentrate. See AR 52, 247, 300. 14 The Ninth Circuit has “established a two-step analysis for determining the extent 15 to which a claimant’s symptom testimony must be credited.” Trevizo v. Berryhill, 871 16 F.3d 664, 678 (9th Cir. 2017). The ALJ must first determine whether the claimant has 17 presented objective medical evidence of an impairment that “could reasonably be 18 expected to produce the pain or other symptoms alleged.” Garrison v. Colvin, 759 F.3d 19 995, 1014–15 (9th Cir. 2014). At this stage, the claimant need only show the impairment 20 could reasonably have caused some degree of the symptoms; he does not have to show 21 the impairment could reasonably be expected to cause the severity of symptoms alleged. 22 Id. The ALJ found Plaintiff met this step. AR 22. 23 1 If the claimant satisfies the first step, and there is no evidence of malingering, the 2 ALJ may only reject the claimant’s testimony “by offering specific, clear and convincing 3 reasons for doing so. This is not an easy requirement to meet.” Garrison, 759 F.3d at 4 1014–15. 5 The ALJ erred in rejecting Plaintiff’s testimony regarding the severity of her 6 physical symptoms. An ALJ may reject a claimant’s symptom testimony when it is 7 contradicted by the medical evidence. See Carmickle v. Comm’r, Soc. Sec. Admin., 533 8 F.3d 1155, 1161 (9th Cir. 2008) (citing Johnson v. Shalala, 60 F.3d 1428, 1434 (9th 9 Cir.1995)). But the ALJ must explain how the medical evidence contradicts the 10 claimant’s testimony. See Dodrill v. Shalala, 12 F.3d 915, 918 (9th Cir. 1993). 11 12 The ALJ reasoned the medical evidence contradicted Plaintiff’s physical symptom 13 testimony because it showed improvement. AR 22. But the ALJ failed to give any 14 specifics supporting this reasoning. The ALJ noted Plaintiff was found not disabled as of 15 August 23, 2017, in a prior ALJ decision. See AR 70–86. Plaintiff alleged an onset date 16 in this claim of August 28, 2017, which the ALJ determined was chosen because it was 17 the first treatment date after the prior decision rather than because of a change in 18 functioning. See AR 22–23. The ALJ then concluded the record going forward showed 19 improvement, so Plaintiff must not be disabled. See AR 23. The ALJ failed, however, to 20 point to any evidence after August 23, 2017, documenting improvement. See id. 21 Although the Court may draw inferences from the ALJ’s decision, it is not the job of the 22 Court to comb the administrative record to find conflicts supporting that decision. See 23 1 Burrell v. Colvin, 775 F.3d 1133, 1138 (9th Cir. 2014). 2 The ALJ separately analyzed Plaintiff’s mental limitations, but failed to confront 3 Plaintiff’s actual testimony. The ALJ reasonably determined the evidence showed 4 Plaintiff’s mental health impairment—depression—did not cause significant limitations. 5 See AR 23–24. But Plaintiff did not testify her depression caused her mental limitations; 6 she testified her pain from her physical impairments caused her mental limitations. See 7 AR 52, 247, 300. As discussed above, the ALJ did not adequately analyze the medical 8 evidence regarding Plaintiff’s physical impairments, and thus failed to adequately address 9 Plaintiff’s testimony regarding the cause of her mental limitations. 10 The ALJ further erred in rejecting Plaintiff’s testimony based on her activities of 11 12 daily living. An ALJ may reject a plaintiff’s symptom testimony based on her daily 13 activities if they contradict her testimony or “meet the threshold for transferable work 14 skills.” Orn v. Astrue, 495 F.3d 625, 639 (9th Cir. 2007) (citing Fair v. Bowen, 885 F.2d 15 597, 603 (9th Cir. 1989)).

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Roush v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roush-v-commissioner-of-social-security-wawd-2021.