Schlabs v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedFebruary 22, 2022
Docket3:21-cv-05642
StatusUnknown

This text of Schlabs v. Commissioner of Social Security (Schlabs 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
Schlabs v. Commissioner of Social Security, (W.D. Wash. 2022).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 CINDY S., 9 Plaintiff, Case No. C21-5642-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of her application for Disability Insurance Benefits. 15 Plaintiff contends the administrative law judge (“ALJ”) erred in discounting a medical opinion 16 and her symptom testimony. (Dkt. # 15 at 1.) She also contends that she is entitled to a remand 17 due to a constitutional violation. (Id.) As discussed below, the Court AFFIRMS the 18 Commissioner’s final decision and DISMISSES the case with prejudice. 19 II. BACKGROUND 20 Plaintiff was born in 1965, has a high school diploma, and previously worked as a 21 secretary, health insurance scheduler and membership services representative, and temporary 22 customer service representative. AR at 291. Plaintiff was last gainfully employed in 2015. Id. 23 1 In July 2018, Plaintiff applied for benefits, alleging disability as of January 15, 2014. AR 2 at 259-65. Plaintiff’s application was denied initially and on reconsideration, and Plaintiff 3 requested a hearing. Id. at 188-90, 192-96. After the ALJ conducted a hearing in September 2020 4 (id. at 117-53), the ALJ issued a decision finding Plaintiff not disabled. Id. at 56-67.

5 As the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision is the 6 Commissioner’s final decision. AR at 1-7. Plaintiff appealed the final decision of the 7 Commissioner to this Court. (Dkt. # 4.) 8 III. LEGAL STANDARDS 9 Under 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of social 10 security benefits when the ALJ’s findings are based on legal error or not supported by substantial 11 evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 (9th Cir. 2005). As a 12 general principle, an ALJ’s error may be deemed harmless where it is “inconsequential to the 13 ultimate nondisability determination.” Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012) 14 (cited sources omitted). The Court looks to “the record as a whole to determine whether the error

15 alters the outcome of the case.” Id. 16 “Substantial evidence” is more than a scintilla, less than a preponderance, and is such 17 relevant evidence as a reasonable mind might accept as adequate to support a conclusion. 18 Richardson v. Perales, 402 U.S. 389, 401 (1971); Magallanes v. Bowen, 881 F.2d 747, 750 (9th 19 Cir. 1989). The ALJ is responsible for determining credibility, resolving conflicts in medical 20 testimony, and resolving any other ambiguities that might exist. Andrews v. Shalala, 53 F.3d 21 1035, 1039 (9th Cir. 1995). While the Court is required to examine the record as a whole, it may 22 neither reweigh the evidence nor substitute its judgment for that of the Commissioner. Thomas v. 23 1 Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). When the evidence is susceptible to more than one 2 rational interpretation, it is the Commissioner’s conclusion that must be upheld. Id. 3 IV. DISCUSSION 4 A. The ALJ Did Not Err in Discounting Plaintiff’s Testimony

5 The ALJ summarized Plaintiff’s testimony and explained that he discounted it because: 6 (1) Plaintiff made inconsistent statements about her symptoms and activities, (2) the objective 7 medical evidence does not corroborate Plaintiff’s allegations, (3) Plaintiff used a cane without 8 medical documentation establishing its necessity, and (4) Plaintiff’s use of a cane during a 9 consultative examination constitutes “malingering or impression management.” AR at 60, 62-65. 10 Plaintiff argues that the ALJ failed to provide clear and convincing reasons to discount her 11 testimony, as is required in the Ninth Circuit absent affirmative evidence of malingering. See 12 Burrell v. Colvin, 775 F.3d 1133, 1136-37 (9th Cir. 2014). 13 The parties first dispute whether the ALJ properly found evidence of malingering. The 14 Commissioner argues that because the ALJ found evidence of malingering, he was not obligated

15 to provide clear and convincing reasons to discount Plaintiff’s allegations. (Dkt. # 19 at 18.) 16 Plaintiff notes, correctly, that no doctor diagnosed malingering (dkt. # 15 at 16), but “affirmative 17 evidence of malingering” need not be based on a medical diagnosis. See, e.g., Berry v. Astrue, 18 622 F.3d 1228, 1235 (9th Cir. 2010) (citing Plaintiff’s statements regarding volunteer work and 19 his ability to work as evidence of malingering). 20 The Court need not determine whether the evidence cited by the ALJ constitutes 21 malingering, because even if the evidence cited by the ALJ in this case does not constitute 22 affirmative evidence of malingering, the ALJ provided other legally sufficient to support the 23 ALJ’s discounting of Plaintiff’s testimony. The ALJ referenced various discrepancies in 1 Plaintiff’s statements (AR at 64-65) and, although Plaintiff submitted a declaration to the 2 Appeals Council in an attempt to clarify those inconsistent statements (id. at 381-82), Plaintiff 3 has not shown that the ALJ erred in discounting her testimony based on those discrepancies. See 4 Social Security Ruling (“SSR”) 16-3p, 2017 WL 5180304, at *8 (Oct. 25, 2017) (indicating that

5 ALJs may “consider the consistency of the [claimant’s] own statements” in evaluating the 6 claimant’s testimony). Plaintiff has not shown that her declaration must be credited nor that it 7 eliminates all inconsistencies in her reporting, and thus it does not undermine the ALJ’s finding 8 that the record contains inconsistent statements regarding Plaintiff’s symptoms. 9 The ALJ also discounted Plaintiff’s testimony that she required the use of an assistive 10 device because this allegation was unsupported by objective medical evidence, which the Ninth 11 Circuit has held is a legally sufficient reason to discount a claimant’s testimony. See, e.g., 12 Thomas, 278 F.3d at 959 (finding that an ALJ did not err in failing to account for a claimant’s 13 alleged need for a cane or wheelchair where no such device had been prescribed for her, and the 14 allegation was therefore unsupported by objective medical evidence); Verduzco v. Apfel, 188

15 F.3d 1087, 1090 (9th Cir. 1999) (affirming an ALJ’s discounting of claimant’s allegations 16 because he used a cane at the hearing “although none of his doctors had ever indicated that he 17 used or needed to use an assistive device in order to walk”); Castenada v. Astrue, 344 F. App’x 18 396, 398 (9th Cir. Sep. 2, 1999) (affirming an ALJ’s discounting of claimant’s allegation that he 19 used a cane and a back brace where he did not use either at the hearing and “no doctor had 20 prescribed the use of a cane”). The ALJ noted that Plaintiff told her provider she used a cane her 21 husband bought at Walmart (AR at 1260), but that no provider had prescribed it, and this 22 undisputed fact reasonably undermines Plaintiff’s allegation that her cane was medically 23 necessary.

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Schlabs v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schlabs-v-commissioner-of-social-security-wawd-2022.