Courtney A. v. Commissioner, Social Security Administration

Summary

The United States District Court for the District of Oregon reviews the denial of disability insurance benefits and supplemental security income to Courtney A. The court finds that the Administrative Law Judge improperly discounted the plaintiff’s subjective migraine-symptom testimony and reverses the Commissioner’s decision. The case is remanded for immediate payment of benefits.

Holdings

1. The ALJ erred by treating a reduction in migraine frequency as inconsistent with Plaintiff's testimony because the record showed continuing one-to-two migraines per month, many lasting multiple days, and continuing serious effects on Plaintiff's ability to work.
2. The ALJ erred in relying on Plaintiff's ability to drive, use public transportation and rideshare services, shop, and manage medication and finances because the ALJ omitted material limitations and did not show that the activities were inconsistent with Plaintiff's claimed migraine limitations.
3. The ALJ erred by relying on findings that Plaintiff was alert and oriented because those findings did not contradict Plaintiff's testimony about migraine-related brain fog and drowsiness.
4. Remand for immediate payment of benefits was appropriate under the Ninth Circuit's credit-as-true framework.

Questions Presented

1. Whether the ALJ provided legally sufficient, clear, and convincing reasons for discounting Plaintiff's subjective symptom testimony concerning migraines.
2. Whether the ALJ improperly relied on partial improvement with treatment, daily activities, and normal mental-status examinations to reject Plaintiff's testimony.
3. Whether the record satisfied the Ninth Circuit's credit-as-true requirements for remand for immediate payment of benefits rather than further administrative proceedings.

Disposition

reversed_and_remanded