Phillip C. v. Commissioner, Social Security Administration

Summary

The United States District Court for the District of Oregon reviewed the Commissioner of Social Security’s denial of disability insurance benefits to Phillip C. The court held that the ALJ improperly evaluated whether the claimant’s chronic headaches medically equaled Listing 11.02, discounted the claimant’s symptom testimony, and rejected the treating provider’s medical opinion. The decision was reversed and remanded for immediate payment of benefits, with disability found as of June 24, 2019.

Holdings

1. The ALJ erred by treating the absence of dyscognitive seizures as dispositive and failing to evaluate whether Plaintiff's headache symptoms were equal in severity and duration to the criteria in Listing 11.02.
2. The ALJ failed to provide specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's testimony concerning the severity and functional effects of his headaches.
3. The ALJ erred in finding Dr. Vanderburgh's opinion unpersuasive because the stated supportability and consistency reasons were not supported by substantial evidence.
4. The credit-as-true standard was satisfied, so remand for immediate payment of benefits was appropriate.

Questions Presented

1. Whether the ALJ properly considered whether Plaintiff's primary headache disorder medically equaled Listing 11.02.
2. Whether the ALJ provided specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom testimony.
3. Whether the ALJ properly evaluated the supportability and consistency of Dr. Vanderburgh's medical opinion.
4. Whether the record satisfied the credit-as-true standard warranting remand for immediate payment of benefits rather than further administrative proceedings.

Disposition

reversed_and_remanded