S. T. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of California reviewed the Commissioner of Social Security’s denial of Plaintiff’s application for disability insurance benefits. The court found reversible errors in the evaluation of Plaintiff’s subjective symptom testimony and several medical-source opinions, while finding no error in the treatment of one consulting physician’s opinion. The court reversed in part, affirmed in part, and remanded for further proceedings and additional fact-finding concerning the residual functional capacity and available jobs.

Holdings

1. The ALJ legally erred by discounting Plaintiff's testimony about the severity of her lower-back pain based on generalized references to less significant objective findings without identifying an actual inconsistency between the testimony and the evidence.
2. The ALJ's error in discounting Plaintiff's lower-back-pain testimony was not harmless.
3. The ALJ erred by failing to include or otherwise account for Dr. Stenbeck's limitations concerning interactions with supervisors and the ability to complete a normal workday or workweek without interruption.
4. The ALJ did not err in finding Dr. Sharma's opinion concerning standing and walking limitations unpersuasive.
5. The ALJ erred by failing to address twelve of Dr. Ong's medical opinions, but the error required remand only for consideration of the opinions concerning recognizing and correcting mistakes or identifying and solving problems, and setting realistic goals.
6. Plaintiff's challenge to alleged conflicts between the vocational expert's testimony and the Dictionary of Occupational Titles was moot because remand required new vocational-expert testimony based on a corrected RFC.

Questions Presented

1. Whether the ALJ gave legally sufficient reasons for discounting Plaintiff's testimony concerning chronic lower-back pain and related functional limitations.
2. Whether the ALJ properly accounted for the moderate mental-work limitations identified by examining psychologist Lauri Stenbeck, Psy.D.
3. Whether the ALJ properly evaluated the standing and walking limitations identified by consulting physician Satish Sharma, M.D.
4. Whether the ALJ was required to address all of the medical opinions identified by Plaintiff's physician Timothy Ong, M.D., and whether any omission was harmless.
5. Whether the ALJ properly resolved alleged conflicts between the vocational expert's testimony and the Dictionary of Occupational Titles.

Disposition

reversed_and_remanded