Yolanda S. C. v. Commissioner of Social Security Administration

Summary

The United States District Court for the District of Oregon reviewed the Commissioner of Social Security’s denial of Yolanda C.’s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that the ALJ failed to provide legally sufficient reasons for discounting the plaintiff’s subjective symptom testimony and the opinions of her physician and mental health therapist. The court reversed the Commissioner’s decision and remanded for the calculation and payment of benefits.

Holdings

1. The ALJ erred by discounting plaintiff's subjective symptom testimony without providing specific, clear, and convincing reasons supported by substantial evidence.
2. The ALJ erred by finding Dr. Maly's physical residual-functional-capacity opinions unpersuasive without adequately supporting the findings regarding supportability and consistency.
3. The ALJ erred by finding Anna Lembke's opinions unpersuasive without substantial evidence supporting the conclusions that the opinions were unsupported or inconsistent with the record.
4. The credit-as-true standard was satisfied, and remand for calculation and payment of benefits rather than further administrative proceedings was appropriate.

Questions Presented

1. Whether the ALJ provided legally sufficient, specific, clear, and convincing reasons supported by substantial evidence for discounting plaintiff's subjective symptom testimony.
2. Whether the ALJ properly evaluated the supportability and consistency of the medical opinions of Dr. Annika Maly and Anna Lembke, LPC.
3. Whether the case should be remanded for further administrative proceedings or for calculation and payment of benefits under the credit-as-true doctrine.

Disposition

reversed_and_remanded