Shelley A. v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington grants Plaintiff’s motion for summary judgment and denies the Commissioner’s cross-motion in a Social Security disability benefits action. The court holds that the ALJ failed to provide clear and convincing reasons for discounting Plaintiff’s subjective symptom testimony, requiring reversal and remand for further proceedings, including reconsideration of the step-three analysis.

Holdings

1. The ALJ adequately evaluated the supportability and consistency of the medical opinions of Dr. Zia and NP Adair and permissibly found them unpersuasive.
2. The ALJ failed to provide specific, clear, and convincing reasons supported by the record for discounting Plaintiff's testimony concerning the severity and functional effects of her physical symptoms.
3. The ALJ's step-three findings must be reconsidered on remand because the improper evaluation of Plaintiff's symptom testimony necessarily affected the determination whether Plaintiff's impairments medically equaled Listing 5.06C.
4. The ALJ must reconsider the statements of Plaintiff's spouse and father on remand because the ALJ relied in part on an erroneous interpretation of a medication record when discounting them.
5. The step-five determination must be reevaluated on remand because proper consideration of Plaintiff's symptom testimony could alter the RFC and the limitations presented to the vocational expert.
6. The appropriate remedy is reversal and remand for further administrative proceedings, not an immediate award of benefits.

Questions Presented

1. Whether the ALJ adequately evaluated the medical opinions of Dr. Jasmine Zia and nurse practitioner Marja A. Adair under the applicable supportability and consistency regulations.
2. Whether the ALJ provided legally sufficient reasons for discounting Plaintiff's subjective symptom testimony.
3. Whether the ALJ's step-three analysis of Listing 5.06C was affected by the improper evaluation of Plaintiff's symptom testimony.
4. Whether the ALJ adequately evaluated the lay witness statements of Matt Armstrong and Donald Pearson.
5. Whether the ALJ satisfied the step-five burden to establish that Plaintiff could perform work existing in significant numbers in the national economy.
6. Whether the case should be remanded for an award of benefits or for further administrative proceedings.

Disposition

reversed_and_remanded