Raymond D. v. O'Malley

Summary

The United States District Court for the Northern District of California grants Plaintiff’s motion for summary judgment, denies the Commissioner’s cross-motion, and remands the Social Security disability-benefits case for further proceedings. The court concludes that the ALJ failed to provide specific and legitimate reasons supported by substantial evidence for discounting the opinion of examining psychologist Elizabeth Walser and also addresses the ALJ’s evaluation of Plaintiff’s subjective symptom testimony.

Holdings

1. The ALJ failed to provide specific and legitimate reasons supported by substantial evidence for giving only partial weight to Dr. Walser's examining opinion while giving great weight to Dr. Lace's non-examining opinion.
2. The ALJ failed to provide specific, clear, and convincing reasons for rejecting Plaintiff's subjective symptom testimony, except with respect to one identified statement concerning conflict with supervisors.
3. The court did not decide the merits of the paragraph C and RFC findings because those determinations depended substantially on the ALJ's reconsideration of the medical opinions and subjective symptom testimony.
4. A direct award of benefits was not warranted because the record was uncertain and ambiguous and outstanding issues remained for the agency to resolve.

Questions Presented

1. Whether the ALJ provided legally sufficient reasons supported by substantial evidence for discounting the examining psychologist's medical opinion.
2. Whether the ALJ provided specific, clear, and convincing reasons for rejecting Plaintiff's subjective symptom testimony.
3. Whether the ALJ's paragraph C finding and RFC determination were supported by substantial evidence.
4. Whether the court should remand for further proceedings or direct an award of benefits under the credit-as-true rule.

Disposition

reversed_and_remanded