William Y. v. Martin O'Malley

Summary

The United States District Court for the Northern District of California reviewed the denial of the plaintiff’s application for Social Security disability benefits. The court granted the plaintiff’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded for further proceedings after finding errors concerning step-two impairments, evaluation of medical opinions, the plaintiff’s testimony, the residual functional capacity, and job-number estimates. The court held that the record did not establish that the plaintiff would necessarily be found disabled if the evidence were properly evaluated.

Holdings

1. The ALJ erred by failing to properly consider Plaintiff's carpal tunnel syndrome, lumbar radiculopathy, and neuropathy at step two. Step two is a de minimis screening inquiry, and an impairment may be found non-severe only when the evidence establishes a slight abnormality having no more than a minimal effect on the claimant's ability to work.
2. The ALJ erred by failing to provide an explanation supported by substantial evidence for rejecting Dr. Aoki's opinion regarding Plaintiff's manipulative, sitting, standing, and walking limitations.
3. The ALJ did not err in rejecting Dr. Catlin's opinion because the ALJ adequately explained that the opinion's marked concentration limitations and predicted attendance and treatment problems were inconsistent with Dr. Catlin's clinical observations, testing, and other record evidence.
4. The ALJ erred by failing to identify which portions of Plaintiff's testimony were rejected and by failing to connect the summarized medical evidence to specific testimony, preventing meaningful judicial review.
5. The RFC and vocational-expert hypothetical were not shown to be supported by substantial evidence because they were based on the ALJ's erroneous treatment of the impairments, medical opinions, and Plaintiff's testimony.
6. The ALJ erred by failing to resolve the significant inconsistency between the vocational expert's job-number estimates and Plaintiff's Job Browser Pro estimates, where Plaintiff used the same DOT codes as the vocational expert.

Questions Presented

1. Whether the ALJ erred by failing to properly consider Plaintiff's lumbar radiculopathy, carpal tunnel syndrome, and neuropathy at step two.
2. Whether the ALJ gave legally sufficient, substantial-evidence-supported reasons for discounting treating physician Dr. Aoki's opinion.
3. Whether the ALJ properly evaluated examining psychologist Dr. Catlin's opinion.
4. Whether the ALJ provided legally sufficient, specific, clear, and convincing reasons for rejecting Plaintiff's symptom testimony.
5. Whether the residual functional capacity and vocational-expert hypothetical were supported by a complete evaluation of Plaintiff's limitations.
6. Whether the ALJ was required to resolve the inconsistency between the vocational expert's job-number estimates and Plaintiff's Job Browser Pro estimates.

Disposition

remanded