Willert v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedOctober 21, 2022
Docket3:22-cv-05315
StatusUnknown

This text of Willert v. Commissioner of Social Security (Willert 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
Willert v. Commissioner of Social Security, (W.D. Wash. 2022).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 DARIN W., CASE NO. 3:22-CV-5315-DWC 11 Plaintiff, ORDER REVERSING AND 12 v. REMANDING DEFENDANT’S DECISION TO DENY BENEFITS 13 COMMISSIONER OF SOCIAL SECURITY, 14 Defendant. 15

Plaintiff filed this action, pursuant to 42 U.S.C. § 405(g), for judicial review of the denial 16 of his applications for disability insurance benefits and supplemental security income. Pursuant 17 to 28 U.S.C. § 636(c), Fed. R. Civ. P. 73 and Local Rule MJR 13, the parties have consented to 18 proceed before the undersigned. 19 BACKGROUND 20 Plaintiff filed for disability insurance benefits and supplemental security income in April 21 2019, alleging an amended disability onset date of February 2019. Administrative Record (AR) 22 17, 193, 199. His applications were denied initially (AR 121) and upon reconsideration (AR 126, 23 133). Represented by an attorney, Plaintiff testified at a hearing before an Administrative Law 24 1 Judge (ALJ) on April 16, 2021. AR 12-44. The ALJ then issued a decision granting Plaintiff 2 applications from the date of his 50th birthday—February 25, 2021—onward, but finding 3 Plaintiff was not disabled before then. AR 104. The Appeals Council denied Plaintiff’s request 4 for review on March 2, 2022, making the ALJ’s decision the final decision of the Commissioner.

5 AR 1-4; 20 C.F.R. §§ 404.981, 416.1481. 6 STANDARD 7 Pursuant to 42 U.S.C. § 405(g) this Court may set aside the Commissioner’s denial of 8 social security benefits if the ALJ’s findings are based on legal error or not supported by 9 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 10 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). However, the 11 Commissioner’s decision must be affirmed if it is supported by substantial evidence and free of 12 harmful legal error. 42 U.S.C. § 405(g); Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 13 2008). 14 Substantial evidence “is a highly deferential standard of review.” Valentine v. Comm’r of

15 Soc. Sec. Admin., 574 F.3d 685, 690 (9th Cir. 2009). The U.S. Supreme Court describes it as 16 “more than a mere scintilla.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). “It means—and 17 means only—such relevant evidence as a reasonable mind might accept as adequate to support a 18 conclusion.” Id. (internal quotations omitted). 19 THE ALJ’s FINDINGS 20 The ALJ found Plaintiff suffered from the severe impairments of obesity, alcohol use 21 disorder with cirrhosis of the liver, ascites due to alcoholic cirrhosis, lumbar degenerative disc 22 disease, and umbilical hernia status post repair. AR 106. 23

24 1 The ALJ determined that Plaintiff had a residual functional capacity (RFC) to perform 2 sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a) except: he cannot climb 3 ladders, ropes, or scaffolds; he can only occasionally climb ramps and stairs, stoop, kneel, 4 crouch, and crawl; he cannot work around hazards such as unprotected heights and exposed

5 moving mechanical parts; and he cannot tolerate more than occasional exposure to extreme cold 6 or vibration. 7 At step five of the sequential evaluation the ALJ determined that prior to February 25, 8 2021 (when Plaintiff’s age category changed), he remained capable of performing jobs that 9 existed in significant numbers in the national economy such as Assembler, Sorter, and Visual 10 Inspector. AR 114. 11 DISCUSSION 12 The issue presented by this case is whether the ALJ erred in his determination that 13 Plaintiff was not disabled until his 50th birthday, as such an error would entitle Plaintiff to 14 approximately two years of retroactive benefits.

15 Plaintiff claims the ALJ erred in his assessment of Plaintiff’s subjective reporting about 16 how symptoms of cirrhosis of the liver impact his functional capacity as well as his assessment 17 of Plaintiff’s treating physician’s opinion regarding the same, and by failing to address the lay 18 witness report submitted by Plaintiff’s brother. As discussed in more detail below, Plaintiff 19 testified that as a result of the edema he experienced in his lower extremities he needed to elevate 20 his legs throughout the day. Plaintiff’s treating physician concurred, and also opined that 21 Plaintiff would need to lie down for several hours a day due to his ascites and edema and that he 22 would miss more than four days of work per month. Plaintiff’s brother submitted a statement 23 documenting his observations of Plaintiff’s difficulties caused by swelling in his legs and feet.

24 1 I. The ALJ failed to provide clear and convincing reasons to discount Plaintiff’s reported need to elevate his legs throughout the day. 2 In May 2019 Plaintiff wrote on a social security administration function report that he 3 was unable to stand and walk for a long period of time or for any distance. AR 241. He further 4 indicated that “swollen feet and legs” also impact his ability to squat, kneel, and climbs stairs, 5 and that he is “able to walk maybe 100 yards” before needing to rest or sit. AR 246. 6 By August 2019 the swelling in his legs and feet had become more severe causing him 7 “reduced mobility” and the need to elevate his legs more throughout the day. AR 260. 8 At the administrative hearing Plaintiff testified that he could sit in a regular desk chair for 9 approximately 45 minutes before needing “to go to the recliner and elevate [his] feet.” AR 27. 10 He estimated at that time he could stand for 10 to 15 minutes before he would need to elevate his 11 feet or use the restroom due to the side-effects of his medication. AR 26. 12 The ALJ found Plaintiff’s subjective reporting, generally, to be “less than fully consistent 13 with the record.” AR 111. The ALJ explained that Plaintiff’s activities of daily living were “not 14 entirely consistent with the extreme limitations he has alleged” (AR 11) and that “treatment has 15 been relatively minimal through the relevant period with documentation of missed follow up 16 appointments” and examinations that “have revealed some edema” but were “largely 17 unremarkable.” Id. 18 Plaintiff argues these were not specific, clear, and convincing reasons to reject Plaintiff’s 19 subjective need to elevate his legs throughout the day. Dkt. 10 at 6. This Court concurs. 20 When assessing the reliability of a claimant’s disability allegations, an ALJ considers the 21 extent to which such allegations are consistent with the objective evidence and other evidence in 22 the record. 20 C.F.R. §§ 404.1529(c), 416.929(c).

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Willert v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/willert-v-commissioner-of-social-security-wawd-2022.