Rancourt v. O'Malley
1:23-cv-05770
N.D. Cal.Mar 11, 2025Background
- Plaintiff challenged the denial of her Social Security disability benefits by the Social Security Administration (SSA).
- The ALJ (Administrative Law Judge) found Plaintiff not disabled, concluding she could perform alternative work despite her impairments.
- Plaintiff stopped working after traumatic circumstances and has a documented history of PTSD and other mental health issues.
- The ALJ did not consider Plaintiff's PTSD as a severe impairment at Step Two of the disability evaluation process or in subsequent RFC (Residual Functional Capacity) analysis.
- The case was fully briefed, and both parties consented to magistrate jurisdiction; the matter was decided on the administrative record and parties’ briefs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's failure to consider PTSD at Step Two | ALJ erred by not finding PTSD severe, ignoring substantial evidence | Omission was harmless; other mental impairments were considered | ALJ's failure was legal error; not harmless; remand required |
| ALJ's failure to consider PTSD in Step Three or RFC | PTSD not properly evaluated at Step Three or RFC formulation | Plaintiff not prejudiced; diagnoses inconsistent | Error in both areas; ALJ did not substantiate determinations with the evidence |
| Duty to develop the record | ALJ failed duty to develop record fully/fairly on mental impairments | ALJ's review sufficient; record adequate | ALJ's duty heightened for mentally ill claimants; not fulfilled here |
| Consideration of other arguments | All errors prejudiced claim and need review | Remaining issues moot if remanded | Further development required; other issues to be addressed on remand |
Key Cases Cited
- Flaten v. Sec'y of Health & Human Servs., 44 F.3d 1453 (9th Cir. 1995) (scope of review for Social Security appeals is limited to substantial evidence and legal error)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (defines substantial evidence in administrative law context)
- Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (court must consider entire record, including evidence detracting from conclusion)
- Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (ALJ's decision upheld if based on rational interpretation)
- Bowen v. Yuckert, 482 U.S. 137 (1987) (Step Two is a de minimis test only to screen out truly groundless claims)
- Edlund v. Massanari, 253 F.3d 1152 (9th Cir. 2001) (Step Two non-severity standard)
- Webb v. Barnhart, 433 F.3d 683 (9th Cir. 2005) (Step Two is a very low threshold for severity)
- Mayes v. Massanari, 276 F.3d 453 (9th Cir. 2001) (ALJ has special duty to develop record, especially with mentally ill claimants)
- Tonapetyan v. Halter, 242 F.3d 1144 (9th Cir. 2001) (ALJ's duty to inquire further when record is ambiguous or inadequate)
- Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (Step Two only weeds out the most minor impairments)