(SS) Decker v. Commissioner of Social Security
2:23-cv-00009-AC
E.D. Cal.Feb 21, 2024Background
- Plaintiff Shauna Decker applied for Supplemental Security Income (SSI) benefits on behalf of her minor child (M.D.), alleging disability due to ADHD and high anxiety starting December 2019.
- The application for benefits was denied initially and upon reconsideration by the Social Security Administration (SSA).
- An Administrative Law Judge (ALJ) held a hearing and found M.D. was not disabled under the Social Security Act, a finding later upheld by the Appeals Council.
- Plaintiff sought judicial review, challenging the ALJ’s decision, specifically the evaluation of subjective testimony and medical opinions.
- The district court reviewed cross-motions for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ’s evaluation of subjective symptom testimony | ALJ failed to specifically link record evidence to rejected symptom testimony. | ALJ properly explained credibility decisions and made specific findings. | Court agreed with Plaintiff; ALJ opinions lacked specific linkage and rationale. |
| Consideration of Consultative Examiner (Dr. Stenbeck) | ALJ improperly rejected ‘marked’ limitations without support; cherry-picked opinion. | ALJ’s rejection supported by overall record; later evidence contradicted Dr. Stenbeck. | Court found ALJ failed to explain why contradictory evidence outweighed Dr. Stenbeck’s opinion; remand required. |
| Consideration of Non-Examining Physician (Dr. Lipetz) | ALJ gave inappropriate weight to opinion based on limited record, conflicted with step two findings. | ALJ could accept functional limitations opinions even if diagnosis conflicted. | Court agreed with Plaintiff on inadequate explanation; lack of clarity necessitated remand. |
| Remedy | Remand required due to harmful legal error. | Judgment for Commissioner; affirm denial. | Remand for further proceedings ordered. |
Key Cases Cited
- Howard ex rel. Wolff v. Barnhart, 341 F.3d 1006 (9th Cir. 2003) (standard of review for SSA decisions)
- Andrews v. Shalala, 53 F.3d 1035 (9th Cir. 1995) (substantial evidence standard)
- Merrill ex rel. Merrill v. Apfel, 224 F.3d 1083 (9th Cir. 2000) (criteria for childhood SSI disability)
- Desrosiers v. Secretary of HHS, 846 F.2d 573 (9th Cir. 1988) (reviewing record as a whole, weighing supporting and detracting evidence)
- Matthews v. Shalala, 10 F.3d 678 (9th Cir. 1993) (diagnosis alone does not establish functional limitations)
- Stout v. Commissioner, 454 F.3d 1050 (9th Cir. 2006) (harmless error standard in SSA determinations)