Tiffany H. v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJune 25, 2026
Docket3:25-cv-05882
StatusUnknown

This text of Tiffany H. v. Commissioner of Social Security (Tiffany H. 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
Tiffany H. 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 TIFFANY H., CASE NO. 3:25-CV-5882-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 certain medical opinion evidence. Had the ALJ properly considered this evidence, Plaintiff’s 19 residual functional capacity (“RFC”) may have included additional limitations or the ultimate 20 determination of disability may have changed. The ALJ’s error is, therefore, not harmless, and 21 this matter is reversed and remanded pursuant to sentence four of 42 U.S.C. § 405(g) to the 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 Commissioner of Social Security (“Commissioner”) for further proceedings consistent with this 2 order. 3 I. Factual and Procedural History 4 Plaintiff unsuccessfully applied for disability benefits in 2007, 2010, and 2014.2 See Dkt.

5 7, Administrative Record (“AR”) 83–158. Plaintiff protectively filed a new application for SSI 6 on October 15, 2018, alleging disability beginning on January 1, 1999. AR 365–76. Through 7 counsel, she later amended the alleged date of disability onset to the protective filing date. AR 8 51. Her application was denied at the initial level and on reconsideration. AR 159–72, 189–98. 9 She requested a hearing before an ALJ, which took place on June 14, 2022. AR 43–70, 199–202. 10 A second hearing was held on January 10, 2023. AR 71–82. Plaintiff was represented by counsel 11 at the hearings. See AR 43, 71. On February 8, 2023, the ALJ issued an unfavorable decision 12 denying benefits. AR 15–42. The Appeals Council denied Plaintiff’s request for review. AR 1–7. 13 Plaintiff appealed to this Court, which remanded the case for further proceedings. AR 835–40. 14 Another hearing took place on May 8, 2025. AR 775–99. On June 17, 2025, the ALJ issued

15 another unfavorable decision finding Plaintiff had not been under a disability since October 15, 16 2018. AR 739–74. Plaintiff again appealed to this Court. See Dkts. 1, 5. 17 In the final decision dated June 17, 2025, the ALJ found Plaintiff had the severe 18 impairments of affective disorder, anxiety disorder, and personality disorder. AR 746. Despite 19 these impairments, the ALJ found Plaintiff had the RFC to perform a full range of work at all 20 exertional levels with specific nonexertional limitations: “she can understand, remember, and 21 22 23 2 In the most recent decision, the ALJ found the presumption of continuing non-disability had been rebutted. AR 24 743. 1 carry out simple and detailed instructions that can be learned in 30 days or less. She can have 2 occasional contact with the general public and coworkers and supervisors.” AR 750. 3 II. Standard of Review 4 When reviewing the Commissioner’s final decision under 42 U.S.C. § 405(g), this Court

5 may set aside the denial of social security benefits if the ALJ’s findings are based on legal error 6 or are not supported by substantial evidence in the record. Bayliss v. Barnhart, 427 F.3d 1211, 7 1214 n.1 (9th Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). Substantial 8 evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a 9 conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (quoting Consol. Edison Co. v. NLRB, 10 305 U.S. 197, 229 (1938)). “We review only the reasons provided by the ALJ in the disability 11 determination and may not affirm the ALJ on a ground upon which he did not rely.” Garrison v. 12 Colvin, 759 F.3d 995, 1010 (9th Cir. 2014). 13 “[H]armless error principles apply in the Social Security Act context.” Molina v. Astrue, 14 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. § 404.1502(a).

15 Generally, an error is harmless if it is not prejudicial to the claimant and is “inconsequential to 16 the ultimate nondisability determination.” Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 17 1055 (9th Cir. 2006); see also Molina, 674 F.3d at 1115. 18 III. Discussion 19 Plaintiff argues the ALJ erred in evaluating certain medical opinion evidence and 20 Plaintiff’s testimony about the severity of her symptoms. Dkt. 15 at 1. She contends the proper 21 remedy for these errors is remand for an award of benefits. Id. 22 23

24 1 A. Medical Opinion Evidence 2 Plaintiff contends the ALJ erred in evaluating medical opinion evidence from K.M. 3 Mansfield-Blair, Ph.D.; Wendy Hartinger, Psy.D.; and LMHC Pat Beck. Dkt. 15 at 1. When 4 evaluating medical opinion evidence, ALJs “will not defer or give any specific evidentiary

5 weight, including controlling weight, to any medical opinion(s) or prior administrative medical 6 finding(s). . . .” 20 C.F.R. §§ 404.1520c(a), 416.920c(a).3 Instead, ALJs must consider every 7 medical opinion or prior administrative medical finding in the record and evaluate the 8 persuasiveness of each one using specific factors. Id. §§ 404.1520c(a), 416.920c(a). 9 The two most important factors affecting an ALJ’s determination of persuasiveness are 10 the “supportability” and “consistency” of each opinion. Id. §§ 404.1520c(a), 416.920c(a). 11 “Supportability means the extent to which a medical source supports the medical opinion by 12 explaining the ‘relevant . . . objective medical evidence.’” Woods v. Kijakazi, 32 F.4th 785, 791– 13 92 (9th Cir. 2022) (quoting 20 C.F.R. § 404.1520c(c)(1)); see also 20 C.F.R. § 416.920c(c)(1). 14 An opinion is more “supportable,” and thus more persuasive, when the source provides more

15 relevant “objective medical evidence and supporting explanations” for their opinion. 20 C.F.R. 16 §§ 404.1520c(c)(1), 416.920c(c)(1).

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