Sophy N. v. Commissioner of Social Security

District Court, W.D. Washington·Decided April 15, 2026·No. 2:25-cv-02389·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA CASE NO. 2:25-CV-02389-DWC Plaintiff, v. ORDER REVERSING AND REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS Defendant.

Plaintiff filed this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of Defendant’s denial of his application for supplemental security income (“SSI”).1 Had the post- hearing submission of the medical opinion been considered, the residual functional capacity (“RFC”) may have included additional limitations, or the ultimate determination of disability may have changed. This error is, therefore, not harmless, and this matter is reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the Commissioner of the Social Security Administration for further proceedings consistent with this order. 1 Pursuant to 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties have consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 2. I. Procedural History Plaintiff filed his application for SSI on September 30, 2019. AR 194. His claim was denied initially on February 26, 2021, and upon reconsideration on October 7, 2021. AR 194, 199. A hearing was held before ALJ Virginia Robinson on September 13, 2022, and on March

31, 2023, ALJ Cecilia LaCara2 (“the ALJ”) issued a decision denying Plaintiff’s claim. AR 140, 209–27. That decision was remanded by the Appeals Council on January 12, 2024. AR 233. The matter came on for a second hearing on September 9, 2024, and by decision entered December 5, 2024, the ALJ again concluded that Plaintiff was not disabled. AR 17–30. From this decision, Plaintiff filed a complaint with this Court on December 2, 2025, seeking judicial review of the ALJ’s decision denying benefits. Dkt. 5. II. Standard of Review Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of social security benefits if the ALJ’s findings are based on legal error or are not supported by substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th

Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (citation omitted). “We review only the reasons provided by the ALJ in the disability determination and may not affirm the ALJ on a ground upon which [they] did not rely.” Garrison v. Colvin, 759 F.3d 995, 1010 (9th Cir. 2014). “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a).

2 ALJ Virginia Robinson was “unavailable due to an extended absence of 20 or more days” and the case was “reassigned to be decided by the undersigned, Administrative Law Judge Cecilia LaCara” pursuant to “HALLEX I- 2-1-55(F)(2).” AR 212. Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. III. Discussion

In his Opening Brief, Plaintiff argues that “[t]he ‘new and material’ evidence submitted to the Appeals Council undermines the ALJ’s determination[,] warranting a remand in order for the ALJ to consider the evidence.” Dkt. 10 at 3. Specifically, Plaintiff alleges that “[t]here is a reasonable probability that[,] had the ALJ had an opportunity to review” the medical opinion of Dr. Melisa Mulick (“Dr. Mulick”), “it would have changed the outcome of the case because the opinion includes greater limitations than those accounted for in the RFC.” Id. at 5. For SSI applications filed after March 27, 2017, in evaluating medical opinion evidence, ALJs “will not defer or give any specific evidentiary weight, including controlling weight, to any medical opinion(s) or prior administrative medical finding(s).” 20 C.F.R. §§ 404.1520c(a), 416.920c(a). Rather, the ALJ must consider every medical opinion or prior administrative

medical finding in the record and evaluate the persuasiveness of each opinion using specific factors. Id. The critical factors in an ALJ’s determination of persuasiveness are the “supportability” and “consistency” of each opinion. Id. §§ 404.1520c(b)(2), 416.920c(b)(2). “Supportability means the extent to which a medical source supports the medical opinion by explaining the ‘relevant . . . objective medical evidence.’” Woods v. Kijakazi, 32 F.4th 785, 791–92 (9th Cir. 2022) (quoting 20 C.F.R. § 404.1520c(c)(1)); see also 20 C.F.R. § 416.920c(c)(1). A medical opinion is more “supportable,” and therefore, more persuasive, when the sources provide ample relevant “objective medical evidence and supporting explanations” for the medical opinion. Woods, 32 F.4th at 793 n.4. “Consistency means the extent to which a

medical opinion is ‘consistent . . . with the evidence from other medical sources and nonmedical sources in the claim.’” Id. at 792 (quoting 20 C.F.R. § 404.1520c(c)(2)); see also 20 C.F.R. § 416.920c(c)(2). An ALJ must articulate “how [they] considered the supportability and consistency factors for a medical source’s opinion” when making their decision. 20 C.F.R. §§

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

Sophy N. v. Commissioner of Social Security, (W.D. Wash. 2026).

Sophy N. v. Commissioner of Social Security (Sophy N. v. Commissioner of Social Security) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related