Summary
The United States District Court for the Western District of Washington reviewed the denial of Remi S.'s applications for Supplemental Security Income and Disability Insurance Benefits. The court held that the Administrative Law Judge failed to provide legally sufficient reasons for discounting the plaintiff's subjective symptom testimony and lay witness statements. The court reversed the agency decision and remanded the matter for further administrative proceedings under sentence four of 42 U.S.C. § 405(g).
Holdings
- The ALJ failed to provide specific, clear, and convincing reasons for rejecting Plaintiff's testimony about the extent of his panic attacks.
- The ALJ did not provide germane reasons for rejecting the lay witness statements.
Questions Presented
- Whether the ALJ erroneously assessed Plaintiff's subjective symptom testimony
- Whether the ALJ properly considered lay witness statements
- Whether the ALJ properly assessed a medical opinion from Dr. Margaret Cunningham
- Whether the ALJ's Residual Functional Capacity (RFC) assessment was deficient
Disposition
reversed_and_remanded
Cases Cited (20)
- Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th Cir. 2005)(cited)
- Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)(cited)
- Garrison v. Colvin, 759 F.3d 995, 1014–15 (9th Cir. 2014)(applied)
- Smolen v. Chater, 80 F.3d 1273, 1281 (9th Cir. 1996)(cited)
- Smolen v. Chater, 80 F.3d 1273, 1284 (9th Cir. 1996)(applied)
- Smolen v. Chater, 80 F.3d 1273, 1284 n.7 (9th Cir. 1996)(applied)
- Connett v. Barnhart, 340 F.3d 871, 874 (9th Cir. 2003)(applied)
- Smartt v. Kijakazi, 53 F.4th 489, 498 (9th Cir. 2022)(applied)
- Burch v. Barnhart, 400 F.3d 676, 681 (9th Cir. 2005)(cited)
- Fair v. Bowen, 885 F.2d 597, 604 (9th Cir. 1989)(applied)
Showing top 10 of 20.
Cited In (0)
No citing cases on record yet.