Vaughn v. Commissioner of Social Security

CourtDistrict Court, E.D. Washington
DecidedApril 24, 2020
Docket2:19-cv-00214
StatusUnknown

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

Bluebook
Vaughn v. Commissioner of Social Security, (E.D. Wash. 2020).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Apr 24, 2020

3 UNITED STATES DISTRICT COURT SEAN F. MCAVOY, CLERK EASTERN DISTRICT OF WASHINGTON 4 LISA V., No. 2:19-cv-00214-SMJ 5 Plaintiff, 6 ORDER GRANTING PLAINTIFF’S v. MOTION FOR SUMMARY 7 JUDGMENT AND DENYING THE COMMISSIONER OF SOCIAL COMMISSIONER’S MOTION 8 SECURITY, FOR SUMMARY JUDGMENT

9 Defendant.

11 Plaintiff Lisa V. appeals the Administrative Law Judge’s (ALJ) denial of her 12 application for Supplemental Security Income (SSI) benefits. She alleges the ALJ 13 (1) improperly evaluated the opinions of an examining physician, and (2) erred in 14 discounting her own subjective symptom testimony. The Commissioner of Social 15 Security (“Commissioner”) asks the Court to affirm the ALJ’s decision. Before the 16 Court, without oral argument, are the parties’ cross-motions for summary judgment, 17 ECF Nos. 10, 11. Upon reviewing the administrative record, the parties’ briefs, and 18 the relevant authority, the Court is fully informed. For the reasons set forth below, 19 the Court agrees with Plaintiff that the ALJ erred in evaluating both the medical 20 opinion evidence and Plaintiff’s symptom testimony. Although these errors 1 invalidated the ALJ’s conclusion that Plaintiff did not qualify for benefits, 2 Plaintiff’s entitlement is not clear from the face of the record. Accordingly, the

3 Court grants Plaintiff’s motion for summary judgment, denies the Commissioner’s 4 motion for summary judgment, and remands for further proceedings. 5 BACKGROUND1

6 Plaintiff applied for benefits on December 19, 2016, alleging disability with 7 an onset date of August 8, 2016. AR 165–66.2 The Commissioner denied Plaintiff’s 8 application on January 24, 2017, see AR 59–66, and denied it again on 9 reconsideration, see AR 68–80. At Plaintiff’s request, a hearing was held before

10 ALJ Mark Kim. AR 31–58. The ALJ denied Plaintiff benefits on September 12, 11 2018. AR 12–30. The Appeals Council denied Plaintiff’s request for review on 12 May 13, 2019. AR 1–6. Plaintiff then appealed to this Court under 42 U.S.C.

13 § 405(g). ECF No. 1. 14 DISABILITY DETERMINATION 15 A “disability” is defined as the “inability to engage in any substantial gainful 16 activity by reason of any medically determinable physical or mental impairment

17 which can be expected to result in death or which has lasted or can be expected to 18

19 1 The facts, thoroughly stated in the record and the parties’ briefs, are only briefly summarized here. 20 2 References to the administrative record (AR), ECF No. 7, are to the provided page numbers to avoid confusion. 1 last for a continuous period of not less than twelve months.” 42 U.S.C. 2 §§ 423(d)(1)(A), 1382c(a)(3)(A). The decision-maker uses a five-step sequential

3 evaluation process to determine whether a claimant is disabled. 20 C.F.R. 4 §§ 404.1520, 416.920. 5 Step one assesses whether the claimant is engaged in substantial gainful

6 activities. If he is, benefits are denied. 20 C.F.R. §§ 404.1520(b), 416.920(b). If he 7 is not, the decision-maker proceeds to step two. 8 Step two assesses whether the claimant has a medically severe impairment or 9 combination of impairments. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant

10 does not, the disability claim is denied. If the claimant does, the evaluation proceeds 11 to the third step. 12 Step three compares the claimant’s impairment with a number of listed

13 impairments acknowledged by the Commissioner to be so severe as to preclude 14 substantial gainful activity. 20 C.F.R. §§ 404.1520(d), 404 Subpt. P App. 1, 15 416.920(d). If the impairment meets or equals one of the listed impairments, the 16 claimant is conclusively presumed to be disabled. If the impairment does not, the

17 evaluation proceeds to the fourth step. 18 Step four assesses whether the impairment prevents the claimant from 19 performing work he has performed in the past by examining the claimant’s residual

20 functional capacity, or RFC. 20 C.F.R. §§ 404.1520(e), 416.920(e). If the claimant 1 is able to perform his previous work, he is not disabled. If the claimant cannot 2 perform this work, the evaluation proceeds to the fifth step.

3 Step five, the final step, assesses whether the claimant can perform other 4 work in the national economy in view of his age, education, and work experience. 5 20 C.F.R. §§ 404.1520(f), 416.920(f); see Bowen v. Yuckert, 482 U.S. 137 (1987).

6 If the claimant can, the disability claim is denied. If the claimant cannot, the 7 disability claim is granted. 8 The burden of proof shifts during this sequential disability analysis. The 9 claimant has the initial burden of establishing a prima facie case of entitlement to

10 disability benefits. Rhinehart v. Finch, 438 F.2d 920, 921 (9th Cir. 1971). The 11 burden then shifts to the Commissioner to show (1) the claimant can perform other 12 substantial gainful activity, and (2) that a “significant number of jobs exist in the

13 national economy,” which the claimant can perform. Kail v. Heckler, 722 14 F.2d 1496, 1498 (9th Cir. 1984). A claimant is disabled only if his impairments are 15 of such severity that he is not only unable to do his previous work but cannot, 16 considering his age, education, and work experiences, engage in any other

17 substantial gainful work which exists in the national economy. 42 U.S.C. 18 §§ 423(d)(2)(A), 1382c(a)(3)(B). 19 ALJ FINDINGS

20 At step one, the ALJ found Plaintiff had not engaged in substantial gainful 1 activity since the alleged onset date of August 6, 2016. AR 17. 2 At step two, the ALJ found that Plaintiff had three medically determinable

3 severe impairments: cerebrovascular accident, left eye trochlear nerve palsy, and 4 antiphospholipid antibody syndrome. Id. The ALJ found neither Plaintiff’s sleep 5 apnea, which was aggravated by alcohol, nor her intermittent migraines were severe

6 impairments. AR 17–18. 7 At step three, the ALJ found that Plaintiff did not have an impairment or 8 combination of impairments that met or medically equaled the severity of a listed 9 impairment. AR 18.

10 At step four, the ALJ found that Plaintiff had an RFC sufficient to perform a 11 restricted range of light work as defined in 20 C.F.R. § 404.1567(b) with the 12 following limitations:

13 [Plaintiff] can lift and carry a maximum of 10 pounds frequently and a maximum of 20 pounds occasionally. She can sit for a total of eight 14 hours in an eight-hour workday with normal breaks. [Plaintiff] can stand and walk for a total of six hours in an eight-hour workday with 15 normal breaks. She can never climb ladders, ropes, or scaffolds or balance. She can occasionally climb ramps and stairs.

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Vaughn v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vaughn-v-commissioner-of-social-security-waed-2020.