Majalca-Williams v. Commissioner of Social Security Administration, 4:24-cv-00385

Dionne Majalca-Williams filed for Social Security disability benefits, alleging disability since February 2018 due to Wegener’s granulomatosis, fibromyalgia, systemic vasculitis, anxiety, and PTSD.
Her initial application and request for reconsideration were denied by the Commissioner; a hearing before an ALJ concluded she was not disabled.
On judicial review, the District Court remanded the case, finding errors in how the ALJ discounted Plaintiff’s symptoms and assessed her fibromyalgia and related medical evidence.
On remand, the ALJ again denied the claim, repeating legal and factual errors related to the assessment of fibromyalgia and Plaintiff’s symptom testimony.
Plaintiff returned to District Court, arguing that the ALJ did not follow remand instructions and again improperly rejected medical and testimonial evidence supporting disability.
The Magistrate Judge recommended reversing the Commissioner’s decision and remanding for calculation and award of benefits, rather than further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fibromyalgia as a severe medically determinable impairment	ALJ failed to apply proper legal standard and ignored longitudinal evidence supporting fibromyalgia.	ALJ correctly required strict documentation of six+ symptoms by a single diagnosing physician.	ALJ applied incorrect standard; medical evidence supports fibromyalgia as MDI.
Discounting Plaintiff’s symptom testimony	ALJ did not give specific, clear, convincing reasons or cite substantial evidence to reject her symptoms.	ALJ cited improvement with treatment and lack of objective signs as justification for discounting.	ALJ's reasons insufficient and lacked support; symptom testimony improperly discounted.
Remedy: Remand for award of benefits vs. further proceedings	Record fully developed, errors established; further proceedings futile.	Conflicts and ambiguities remain; proper remedy is remand for more proceedings.	Record supports direct award of benefits; all criteria for immediate remand met.

Benecke v. Barnhart, 379 F.3d 587 (9th Cir. 2004) (ALJ erred in demanding objective evidence for fibromyalgia and discounting opinions of treating physicians)
Revels v. Berryhill, 874 F.3d 648 (9th Cir. 2017) (remand for benefits appropriate where ALJ failed to give valid reasons for rejecting treating rheumatologist and claimant’s testimony)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (clear and convincing reasons required to reject claimant's symptom testimony)
Robbins v. Soc. Sec. Admin., 466 F.3d 880 (9th Cir. 2006) (court can reverse for award of benefits if ALJ lacked substantial evidence or made legal error)
Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (outlines five-step evaluation of disability claims)