Sarah J. E. v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedMay 20, 2026
Docket3:25-cv-05833
StatusUnknown

This text of Sarah J. E. v. Commissioner of Social Security (Sarah J. E. 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
Sarah J. E. v. Commissioner of Social Security, (W.D. Wash. 2026).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 SARAH J. E., CASE NO. 3:25-CV-5833-DWC 11 Plaintiff, v. ORDER REVERSING AND 12 REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 13 SECURITY, 14 Defendant.

15 Plaintiff filed this action under 42 U.S.C. § 405(g) seeking judicial review of Defendant’s 16 denial of her application for supplemental security income benefits (“SSI”).1 After considering 17 the record, the Court concludes the Administrative Law Judge (“ALJ”) erred in his evaluation of 18 Plaintiff’s testimony about the severity of her symptoms. Had the ALJ properly considered this 19 evidence, Plaintiff’s residual functional capacity (“RFC”) may have included additional 20 limitations or the ultimate determination of disability may have changed. The ALJ’s error is, 21 therefore, not harmless, and this matter is reversed and remanded pursuant to sentence four of 42 22 23 1 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties have 24 consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 2. 1 U.S.C. § 405(g) to the Commissioner of Social Security (“Commissioner”) for further 2 proceedings consistent with this order. 3 I. Factual and Procedural History 4 Plaintiff unsuccessfully applied for SSI and disability insurance benefits in 2016.2 Dkt. 7,

5 Administrative Record (“AR”) 205–49. She filed a new application for SSI on October 27, 2022, 6 alleging disability beginning on December 18, 2021. AR 499–505. Through her representative, 7 she later amended the alleged onset date to the protective filing date of October 27, 2022. AR 8 626. Her application was denied at the initial level and on reconsideration. AR 305–09, 320–28. 9 She requested a hearing before an ALJ, which took place on September 11, 2024. AR 77–109, 10 331–35. Plaintiff was represented at the hearing. See AR 77. On September 26, 2024, the ALJ 11 issued an unfavorable decision denying benefits. AR 275–98. Then, on October 31, 2024, the 12 Appeals Council granted Plaintiff’s request for review, vacated the ALJ’s decision, and 13 remanded the case back to the ALJ for further proceedings. AR 299–304, 415–18. 14 A second hearing was held on July 16, 2025. AR 43–76. The following day, Plaintiff’s

15 counsel submitted written objections to the vocational expert’s hearing testimony. AR 669–80. 16 On July 25, 2025, the ALJ issued another unfavorable decision finding Plaintiff had not been 17 under a disability from November 17, 2022, through the date of the decision. AR 14–42. The 18 Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the final 19 decision of the Commissioner. AR 1–13, 495–98. Plaintiff appealed to this Court. See Dkts. 1, 5. 20 In the final decision dated July 25, 2025, the ALJ found Plaintiff had the severe 21 impairments of personality disorder, anxiety disorder (with panic disorder), fibromyalgia, 22 depressive disorder, trauma, obesity, and benign joint hypermobility. AR 20. Despite these 23

24 2 In the most recent decision, the ALJ found the presumption of continuing non-disability was rebutted. AR 18. 1 impairments, the ALJ found Plaintiff had the RFC to perform light work as described in 20 2 C.F.R. § 416.967(b) with certain caveats: 3 [Plaintiff can] only occasionally climb ramps and stairs, but never climb ladders, ropes, or scaffolds. The individual can frequently balance, but occasionally stoop, 4 kneel, crouch, and crawl. The individual can frequently handle, finger, and feel bilaterally. The individual can tolerate occasional exposure to workplace hazards 5 such as working in high, exposed places or in proximity to moving mechanical parts. The individual can understand, remember, and carry out simple instructions, 6 and can tolerate occasional contact with coworkers. The individual cannot engage in tasks that requires teamwork or close collaboration with co-workers. The 7 individual can tolerate not [sic] direct interactive contact with the general public. The individual requires regular work breaks at 2-hour intervals. 8 AR 23. 9 II. Standard of Review 10 When reviewing the Commissioner’s final decision under 42 U.S.C. § 405(g), this Court 11 may set aside the denial of social security benefits if the ALJ’s findings are based on legal error 12 or are not supported by substantial evidence in the record. Bayliss v. Barnhart, 427 F.3d 1211, 13 1214 n.1 (9th Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). Substantial 14 evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a 15 conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (quoting Consol. Edison Co. v. NLRB, 16 305 U.S. 197, 229 (1938)). “We review only the reasons provided by the ALJ in the disability 17 determination and may not affirm the ALJ on a ground upon which he did not rely.” Garrison v. 18 Colvin, 759 F.3d 995, 1010 (9th Cir. 2014). 19 “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue, 20 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a). 21 Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to 22 the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 23 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. 24 1 III. Discussion 2 Plaintiff contends the ALJ erred in evaluating certain medical opinion evidence, 3 Plaintiff’s testimony about the severity of her symptoms, and lay witness evidence. Dkt. 10 at 1. 4 She further argues the ALJ relied on erroneous vocational evidence and formulated an

5 incomplete RFC. Id. She contends the proper remedy for these errors is remand for an award of 6 benefits. Id. at 17–18; Dkt. 15 at 10. 7 A. Subjective Symptom Testimony 8 Plaintiff argues the ALJ erred in discounting her testimony about the severity of her 9 symptoms. Dkt. 10 at 9. “An ALJ engages in a two-step analysis to determine whether a 10 claimant’s testimony regarding subjective pain or symptoms is credible.” Garrison, 759 F.3d at 11 1014. At the first step, the ALJ determines whether the claimant has presented objective medical 12 evidence of an underlying impairment that could reasonably be expected to produce the pain or 13 other symptoms alleged. Id. This evidence need not validate the severity of the alleged 14 symptoms; rather, “the medical evidence need only establish that the impairment could

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Sarah J. E. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sarah-j-e-v-commissioner-of-social-security-wawd-2026.