(SS) Williams v. Commissioner of Social Security
1:21-cv-01492
E.D. Cal.May 27, 2025Background
- Tonya Carole Williams applied for Supplemental Security Income (SSI) in March 2019, alleging disability since January 2019 due to mental health conditions.
- Her claim was denied initially, on reconsideration, and after a hearing before an Administrative Law Judge (ALJ) in March 2021.
- The ALJ found Williams had several severe mental impairments but determined she could still perform certain unskilled jobs in the national economy and thus was not disabled.
- Williams sought review in federal court, arguing errors in the ALJ's assessment of her symptom testimony and the weighing of supporting physician opinions.
- The Magistrate Judge found the ALJ failed to apply proper legal standards in evaluating Williams' subjective complaints and recommended reversal and remand for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's assessment of symptoms testimony | ALJ failed to provide clear, convincing reasons to reject her subjective complaints | ALJ properly discounted testimony by referencing inconsistencies and medical evidence | ALJ erred; only lack of supporting evidence used, not enough |
| ALJ's use of inconsistent statements | Inconsistencies cited by ALJ unrelated to work limitations | Inconsistencies validly used in credibility analysis | ALJ's use of inconsistencies not tied to work abilities, error |
| Failure to seek/follow treatment as credibility factor | Noncompliance explained by her mental impairments | Noncompliance shows she understood treatment, not fully impaired | Failure to follow up explained by symptoms; improper to discount |
| Remedy/remand | Immediate award or remand for benefits requested | Further proceedings argued to be necessary | Remand for further proceedings appropriate |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (substantial evidence standard for administrative findings)
- Burkhart v. Bowen, 856 F.2d 1335 (requirement to apply proper legal standards in social security cases)
- Garrison v. Colvin, 759 F.3d 995 (requirements for evaluating claimant's subjective symptom testimony)
- Batson v. Comm’r, 359 F.3d 1190 (ALJ must provide specific, clear, and convincing reasons to reject symptom testimony)
- Tommasetti v. Astrue, 533 F.3d 1035 (ALJ may consider failure to seek treatment as part of credibility assessment)
- Warre v. Comm'r of Soc. Sec. Admin., 439 F.3d 1001 (impairments controllable by medication are not disabling)
- Bray v. Comm'r of Soc. Sec. Admin., 554 F.3d 1219 (review limited to ALJ's stated reasons, not post hoc rationalizations)
- Harman v. Apfel, 211 F.3d 1172 (standards for remand or immediate award of benefits)