Vader v. Social Security Administration

CourtDistrict Court, S.D. California
DecidedMay 14, 2021
Docket3:19-cv-00703-AHG
StatusUnknown

This text of Vader v. Social Security Administration (Vader v. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vader v. Social Security Administration, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 ROSE V., Case No.: 3:19-cv-00703-AHG

12 Plaintiff, ORDER: 13 v. (1) GRANTING IN PART AND 14 ANDREW SAUL, Commissioner of DENYING IN PART DEFENDANT’S Social Security, 15 MOTION TO ALTER OR AMEND Defendant. JUDGMENT PURSUANT TO 16 FEDERAL RULE OF CIVIL 17 PROCEDURE 59(E);

18 (2) VACATING ORDER 19 RESOLVING PLAINTIFF’S MOTION FOR JUDICIAL REVIEW, 20 REVERSING DENIAL OF 21 BENEFITS, AND REMANDING FOR PAYMENT OF BENEFITS (ECF NO. 22 24); AND 23 (3) REMANDING ACTION FOR 24 FURTHER PROCEEDINGS 25 [ECF NOS. 24, 25] 26

27 1 This matter comes before the Court on Defendant Andrew Saul, Commissioner of 2 Social Security’s (“Defendant” or “the Commissioner”) Motion to Alter or Amend 3 Judgment Pursuant to Federal Rule of Civil Procedure 59(e) (the “Motion for 4 Reconsideration”). ECF No. 24. 5 I. BACKGROUND 6 On April 17, 2019, Plaintiff Rose V. (“Plaintiff”), proceeding pro se and in forma 7 pauperis, filed a civil complaint against Defendant, seeking judicial review of the denial 8 of her application for Supplemental Security Income (“SSI”) pursuant to 42 U.S.C. 9 § 405(g). ECF No. 1. 10 Plaintiff submitted a brief on the merits on February 5, 2020, and Defendant filed an 11 opposition brief on March 11, 2020. ECF Nos. 20, 23. Plaintiff did not file a reply. The 12 Court took the briefing under submission without oral argument and, on 13 November 30, 2020, issued an order reversing the Commissioner’s final decision and 14 remanding Plaintiff’s case for immediate payment of benefits (the “Reversal Order”). ECF 15 No. 24. 16 On December 9, 2020, the Commissioner filed the Motion for Reconsideration 17 presently before the Court. ECF No. 25. Defendant argues, pursuant to Rule 59(e), that 18 reconsideration of the Court’s Reversal Order is necessary to correct manifest errors of 19 law. 20 II. LEGAL STANDARD 21 Under Rule 59(e), the Court has the power to reconsider and amend a judgment, and 22 a party seeking such remedy must file a motion within 28 days of the judgment’s entry. 23 See Fed. R. Civ. P. 59(e). Amendment of a judgment pursuant to this rule is an 24 “extraordinary remedy, to be used sparingly in the interests of finality and conservation of 25 judicial resources.” Carroll v. Nakatani, 342 F.3d 934, 945 (9th Cir. 2003) (citation 26 omitted). Accordingly, a Rule 59(e) motion for reconsideration “should not be granted, 27 absent highly unusual circumstances, unless the district court is presented with newly 1 controlling law.” 389 Orange St. Partners v. Arnold, 179 F.3d 656, 665 (9th Cir. 1999). 2 “Clear error occurs when ‘the reviewing court on the entire record is left with the definite 3 and firm conviction that a mistake has been committed.’” Smith v. Clark Cty. Sch. Dist., 4 727 F.3d 950, 955 (9th Cir. 2013) (quoting United States v. U.S. Gypsum Co., 333 U.S. 5 364, 395 (1948)). Parties may not use a Rule 59(e) motion “to raise arguments or present 6 evidence for the first time when they could reasonably have been raised earlier in the 7 litigation.” Kona Enters., Inc. v. Estate of Bishop, 229 F.3d 877, 890 (9th Cir. 2000). 8 III. DISCUSSION 9 In the Reversal Order, the Court based its decision on the finding that the ALJ 10 improperly rejected the opinion of Plaintiff’s treating psychiatrist, Dr. Prakash Bhatia, 11 because the ALJ did not give specific and legitimate reasons supported by substantial 12 evidence for giving his opinion less weight than the non-treating state agency physicians. 13 In particular, the Court cited to numerous treatment records from Dr. Bhatia reflecting 14 observed deficits in Plaintiff’s memory and concentration, and judgments that Plaintiff had 15 serious symptoms or serious impairment in social, occupational, or school functioning. See 16 ECF No. 24 at 14-23. The Court found that the ALJ’s stated reasons for rejecting Dr. 17 Bhatia’s findings related to Plaintiff’s functioning in areas of memory, concentration, and 18 judgment—that Plaintiff’s symptoms steadily improved and that Plaintiff was stable on 19 medication—were not supported by substantial evidence. Id. at 20-23. The Court 20 concluded that reversal and remand for an immediate award of benefits was warranted, 21 based on testimony from the vocational expert at the hearing below that a hypothetical 22 person with an excessive amount of time off-task or with two or more absences per month 23 due to symptoms of her mental health conditions would not be able to perform any jobs 24 existing in significant numbers in the national economy. Id. at 24-25. 25 The Commissioner asserts several grounds of error in the Motion for 26 Reconsideration. Specifically, Defendant contends the Court erred by: (1) considering the 27 clinical findings contained in treatment records of Plaintiff’s treating psychiatrist, Prakash 1 was appropriate, relying on testimony from the vocational expert regarding hypothetical 2 functional limitations posed by Plaintiff’s attorney during the administrative hearing, and 3 attributing those proposed limitations to Dr. Bhatia; and (3) reversing for an award of 4 disability insurance benefits (“DIB”), when Plaintiff applied for SSI and not DIB. 5 In addition, with respect to the first claim of error regarding the Court’s evaluation 6 of the evidence contained in Dr. Bhatia’s treatment records, Defendant raises further 7 related claims of error. Namely, that even if the Court properly treated this evidence as a 8 treating physician’s opinion, (1) the ALJ gave specific and legitimate reasons supported by 9 substantial evidence to reject it; and (2) the rejection was harmless even if erroneous, 10 because Dr. Bhatia did not opine that Plaintiff had mental limitations beyond those that the 11 ALJ incorporated into his determination of Plaintiff’s residual functional capacity 12 (“RFC”). The Court addresses these arguments in Sections III.B. and III.C. before turning 13 to the Commissioner’s remaining claims of error. 14 A. Whether the Court Erred by Treating Dr. Bhatia’s Clinical Findings as Medical Opinion Evidence 15

16 First, Defendant argues the Court committed clear legal error by erroneously 17 conflating objective medical evidence contained in Dr. Bhatia’s treatment records with 18 medical-opinion evidence from Dr. Bhatia. ECF No. 25-1 at 3-4. 19 Agency regulations define “[m]edical opinions” as “statements from acceptable 20 medical sources that reflect judgments about the nature and severity of your impairment(s), 21 including your symptoms, diagnosis and prognosis, what you can still do despite 22 impairment(s), and your physical or mental restrictions.” 20 C.F.R. § 416.927(a)(1). 23 Defendant contends that the record statements that the Court treated as “medical 24 opinions” from Dr. Bhatia should instead have been treated as “objective medical 25 evidence,” which is defined in the regulations as “medical signs, laboratory findings, or 26 both.” Id. at 3 (quoting 20 C.F.R. § 416.913(a)(1)). “Medical signs,” in turn, include 27 “psychological abnormalities that can be observed . . .

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Vader v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vader-v-social-security-administration-casd-2021.