Murphy v. Commissioner Social Security Administration
3:23-cv-01970
| D. Or. | Jan 15, 2025Background
- Plaintiff Tracy M. sought judicial review of the Social Security Administration Commissioner’s denial of her claims for Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI), alleging disability since November 18, 2018.
- Plaintiff's applications were denied twice by an ALJ; after an initial federal court remand, a second hearing again found her not disabled.
- Plaintiff was in her late 20s at onset and had no past relevant work; her impairments included both physical and mental conditions.
- The ALJ found multiple severe impairments but concluded that Plaintiff retained the residual functional capacity (RFC) to perform light work with significant limitations.
- The Commissioner’s denial was challenged on the basis of (1) classification of neurocognitive and post-concussion conditions, (2) rejection of Plaintiff’s subjective symptom testimony, and (3) evaluation of two medical opinions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Step Two Severity of Neurocognitive/Post-Concussion | ALJ failed to recognize these as severe impairments. | ALJ’s error, if any, was harmless since sequential analysis continued. | Any error was harmless; ALJ considered all. |
| Rejection of Subjective Symptom Testimony | ALJ did not give specific, clear, and convincing reasons for rejection. | Testimony inconsistent with record and activities; rationale was sufficient. | ALJ did not err; provided legally adequate reasons. |
| Rejection of Dr. Guastadisegni’s Medical Opinion | ALJ improperly discredited evidence of cognitive limitations. | Opinion inconsistent with records and activities; lacked workplace specificity. | ALJ’s partial rejection was reasonable. |
| Rejection of Beth Stoner’s Counselor Opinion | ALJ cherry-picked record; daily activity rationale invalid; length adequate. | Opinion inconsistent with own notes, unreliable, brief relationship. | ALJ’s discounting supported by substantial evidence. |
Key Cases Cited
- Hammock v. Bowen, 879 F.2d 498 (9th Cir. 1989) (substantial evidence standard for judicial review of SSA decisions)
- Richardson v. Perales, 402 U.S. 389 (1971) (defines substantial evidence for SSA appeals)
- Bowen v. Yuckert, 482 U.S. 137 (1987) (five-step process for SSA disability determination; harmless error at step two)
- Martinez v. Heckler, 807 F.2d 771 (9th Cir. 1986) (court must consider evidence for and against ALJ finding)
- Massachi v. Astrue, 486 F.3d 1149 (9th Cir. 2007) (deference to ALJ’s rational interpretations of evidence)
- Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (upholding ALJ where evidence supports more than one interpretation)
- Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (ALJ must evaluate cumulative effect of impairments)
- Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (two-step process for evaluating claimant's symptom testimony)
- Holohan v. Massanari, 246 F.3d 1195 (9th Cir. 2001) (requirement for specific reasons in rejecting claimant's testimony)
- Ford v. Saul, 950 F.3d 1141 (9th Cir. 2020) (evaluation of the persuasiveness and supportability of medical opinions)