Vanderzanden v. Commissioner Social Security Administration

District Court, D. Oregon·Decided May 15, 2025·No. 3:23-cv-00101·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

EMILY V.,1 Case No. 3:23-cv-101-HL

Plaintiff, ORDER

v.

COMMISSIONER, SOCIAL SECURITY ADMINISTRATION,

Defendant.

Michael H. Simon, District Judge.

United States Magistrate Judge Andrew Hallman issued Findings and Recommendation in this case on September 6, 2024. Judge Hallman recommended that the Court reverse and remand the decision of the Commissioner to deny Plaintiff Emily V.’s application for child disability benefits and supplemental security income. Judge Hallman concluded that the Administrative Law Judge (“ALJ”) erred in evaluating Plaintiff’s subjective symptom testimony because the ALJ failed to evaluate the testimony with sufficient specificity. Judge Hallman also concluded that the ALJ erred in failing to evaluate the medical opinion of Plaintiff’s treating

1 In the interest of privacy, this Order uses only the first name and the initial of the last name of the non-governmental party in this case. When applicable, this Order uses the same designation for a non-governmental party’s immediate family member. physician, Dr. George Anadiotis. Judge Hallman determined that Dr. Anadiotis provided a medical opinion requiring consideration, when the ALJ had erroneously concluded that Dr. Anadiotis had failed to provide any statement relating to Plaintiff’s functioning. Under the Federal Magistrates Act (“Act”), the Court may “accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate.” 28 U.S.C.

§ 636(b)(1). If a party objects to a magistrate judge’s findings and recommendations, “the court shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” Id.; Fed. R. Civ. P. 72(b)(3). For those portions of a magistrate judge’s findings and recommendations to which neither party has objected, the Act does not prescribe any standard of review. See Thomas v. Arn, 474 U.S. 140, 152 (1985) (“There is no indication that Congress, in enacting [the Act], intended to require a district judge to review a magistrate’s report to which no objections are filed.”); United States v. Reyna-Tapia, 328 F.3d 1114, 1121 (9th Cir. 2003) (en banc) (holding that the court must review de novo magistrate judge’s findings and recommendations if objection is made, “but

not otherwise”). Although in the absence of objections no review is required, the Act “does not preclude further review by the district judge[] sua sponte . . . under a de novo or any other standard.” Thomas, 474 U.S. at 154. Indeed, the Advisory Committee Notes to Rule 72(b) of the Federal Rules of Civil Procedure recommend that “[w]hen no timely objection is filed,” the Court review the magistrate judge’s recommendations for “clear error on the face of the record.” The Commissioner timely filed an objection, to which Plaintiff responded. The Commissioner argues that the ALJ offered sufficiently specific reasons to discount Plaintiff’s testimony, including by reciting detailed medical evidence and by mentioning that Plaintiff took over-the-counter medication. The Commissioner also argues that the ALJ correctly discounted Dr. Anadiotis’s opinion because the portions addressing Plaintiff’s limitations were in the “History of Present Illness” section and reflect Plaintiff’s description of their limitations and not Dr. Anadiotis’s evaluation of Plaintiff’s limitations. The Court reviewed de novo the filings in the case and much of the underlying record and addresses each objection in turn. A. Plaintiff’s Testimony The Court agrees with Judge Hallman that the ALJ failed to evaluate Plaintiff’s testimony

with the requisite specificity. An ALJ must specifically identify what evidence contradicted what testimony. See Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1103 (9th Cir. 2014) (stating that an ALJ may not vaguely conclude that “a claimant’s testimony is ‘not consistent with the objective medical evidence,’ without any ‘specific findings in support’ of that conclusion” (quoting Vasquez v. Astrue, 572 F.3d 586, 592 (9th Cir. 2009)). A court “cannot review whether the ALJ provided specific, clear, and convincing reasons for rejecting [a clamaint’s] pain testimony where . . . the ALJ never identified which testimony she found not credible, and never explained which evidence contradicted that testimony.” Lambert v. Saul, 980 F.3d 1266, 1277 (9th Cir. 2020) (emphases in original) (quoting Brown-Hunter v. Colvin, 806 F.3d 487, 494 (9th Cir. 2015)). The ALJ must “identify the testimony she found not credible”

and “link that testimony to the particular parts of the record supporting her non-credibility determination.” Brown-Hunter, 806 F.3d at 494. Failure to do so is legal error. Id. Here, the ALJ did not explain what evidence is inconsistent with Plaintiff’s testimony about their ability to work and which aspects of Plaintiff’s testimony she did not find credible. The Commissioner argues, however, that the ALJ made sufficiently specific findings by referencing medical examinations that did not show limitations that could affect Plaintiff’s ability to work. The Commissioner asserts that the ALJ “highlighted” with specific citations examinations showing that Plaintiff’s joints were not unstable or dislocated, their gait was steady, their motor strength and grip were full in all extremities, and they had normal muscle bulk and tone. But these citations are insufficient for at least three reasons. First, citing specific medical evidence is insufficient without linking those specific medical examinations to testimony. The Ninth Circuit repeatedly has emphasized that an ALJ does not sufficiently evaluate a claimant’s testimony by specifically reciting medical evidence,

and that a court may not rely on that medical testimony and make inferences as to what testimony it contradicts, even if such inferences are logical. See, e.g., Lambert, 980 F.3d at 1278 (stating that “provid[ing] a relatively detailed overview of [a claimant’s] medical history . . . [‘]is not the same as providing clear and convincing reasons for finding the claimant’s symptom testimony not credible’” (emphasis in original) (quoting Brown-Hunter, 806 F.3d at 494)); Treichler, 775 F.3d at 1103 (rejecting the argument that because the ALJ “set out his [residual functional capacity] and summarized the evidence supporting his determination,” the court could infer “that the ALJ rejected [petitioner’s] testimony to the extent it conflicted with that medical evidence”).

Second, when deciding that “objective findings do not suggest [Plaintiff’s] joint problems would cause them to miss work,” the ALJ seemed to exclusively rely on Dr. Derek Leinenbach’s conclusion that Plaintiff suffered no joint instability.2 See AR (ECF 11-1) 428. But

2 In her review of Plaintiff’s medical examinations, the ALJ also discussed examinations conducted by Drs. Jennifer Willingham, Douglas Smyth, Christina Weiss, Susan Moner, Winifred Ju, M. Fountain, and Irmgard Friedburg. The opinions of Drs.

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