Haro v. Commissioner Social Security Administration
6:24-cv-00719
| D. Or. | Apr 11, 2025Background
- Geraldine H. applied for Social Security Disability Insurance Benefits, alleging disability beginning July 1, 2020, due to multiple medical conditions including breast cancer and rheumatoid arthritis.
- The ALJ found she had several severe impairments but concluded she was not disabled, finding she could perform past relevant work as a salesperson.
- Plaintiff’s application was denied at both the initial and reconsideration stages; an administrative hearing also resulted in an unfavorable decision to the plaintiff.
- The parties agree that the ALJ erred by failing to adequately address Dr. Alanna Hannegraf’s medical opinion and its effect on whether plaintiff can perform past relevant work.
- The principal dispute before the court is whether the case should be remanded for immediate payment of benefits or for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to properly consider Dr. Hannegraf’s opinion | ALJ’s failure was harmful and record requires only payment of benefits if Dr. Hannegraf is credited | Record is ambiguous, further consideration needed | ALJ committed error; remand required |
| Scope of remand | Argued for immediate award of benefits | Sought remand for further proceedings | Remanded for further proceedings, not for benefits |
| ALJ's analysis of ability to perform past work | With proper credit to evidence, plaintiff disabled | Necessity of further evidence and reconciliation | ALJ must reconsider, particularly step five analysis |
| Resolution of conflicting medical evidence | Conflicts do not preclude a finding of disability | Conflicts and ambiguities require further development | ALJ to resolve conflicts on remand |
Key Cases Cited
- Holohan v. Massanari, 246 F.3d 1195 (9th Cir. 2001) (discusses court’s discretion to remand for further proceedings or immediate benefits)
- Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090 (9th Cir. 2014) (sets out the utility framework for remand versus benefits)
- Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (addresses the “credit-as-true” rule in social security appeals)
- Dominguez v. Colvin, 808 F.3d 403 (9th Cir. 2015) (discusses steps for remand and award of benefits in disability cases)
- Strauss v. Comm’r of the Soc. Sec. Admin., 635 F.3d 1135 (9th Cir. 2011) (clarifies credit-as-true analysis is required for award of benefits)