Guadalupe M. v. Leland Dudek

Summary

This is an order from the United States District Court for the Southern District of California reviewing the denial of Guadalupe M.'s applications for Social Security disability insurance benefits and supplemental security income. The court upheld the ALJ's assessment of Plaintiff's subjective symptom allegations but found reversible error because the ALJ did not adequately specify the degree of limitation in each mental-function area or explain how the non-severe anxiety disorder was considered in the residual functional capacity assessment. The court ordered reversal of the Commissioner's decision and remand for further administrative proceedings.

Holdings

1. The ALJ provided sufficiently specific, clear, and convincing reasons for partially discounting Plaintiff's allegations concerning dizziness and vertigo because the medical record repeatedly documented that Plaintiff denied those symptoms, contrary to his testimony that he experienced daily, hour-long episodes.
2. The ALJ erred by stating only that Plaintiff had no more than mild limitations in any functional area rather than making a specific finding as to the degree of limitation in each of the four paragraph B functional areas.
3. The ALJ reversibly erred by failing to discuss or explain how Plaintiff's non-severe anxiety and depressive disorders were considered in the RFC assessment.
4. The errors were not harmless because the absence of specific paragraph B ratings and any analysis of the mental impairments in the RFC prevented the court from determining whether the RFC was supported by substantial evidence.

Questions Presented

1. Whether the ALJ provided specific, clear, and convincing reasons for discounting Plaintiff's subjective allegations concerning pain, dizziness, and vertigo.
2. Whether the ALJ properly applied the special psychiatric review technique by assigning specific ratings to each paragraph B functional area.
3. Whether the ALJ was required to explain how Plaintiff's non-severe anxiety and depressive disorders were considered in the residual functional capacity assessment.
4. Whether the ALJ's errors were harmless.

Disposition

reversed_and_remanded