William Y. v. O'Malley
- Kandis Westmore
- 4:23-cv-06158
- U.S. District Court · Northern District of California
- 11
In William Y. v. O'Malley, Judge Westmore granted William Y.'s motion, denied the Commissioner's motion, and remanded the disability-benefits decision.
William Y. and the Commissioner of Social Security are affected. The case returns to the Administrative Law Judge for further proceedings; the order does not direct an award of benefits.
What happened
In William Y. v. O'Malley, William Y. asked the court to review the denial of his application for disability benefits. The Administrative Law Judge had denied the application, and the Appeals Council declined further review. William Y. challenged the treatment of his medical conditions, medical opinions, testimony, work capacity, vocational-expert testimony, and job estimates.
The court found several errors. The Administrative Law Judge did not properly consider certain conditions at the initial severity step, gave inadequate reasons for rejecting treating physician Maki Aoki's opinion, and did not clearly explain why William Y.'s testimony was rejected. The court found no error in the treatment of examining psychologist Laura Jean Catlin's opinion. It also found that the work-capacity assessment and job estimates required further consideration.
Judge Kandis Westmore granted William Y.'s motion for summary judgment and denied the Commissioner's cross-motion for summary judgment. The court remanded the case for further proceedings because the record did not establish that William Y. must be found disabled after the evidence is properly evaluated.
The detailed version
- William Y. v. O'Malley · No. 4:23-cv-06158
- Kandis Westmore
- Mar. 27, 2025
Background
William Y. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner's final decision denying his application for Title XVI benefits. The Social Security Administration denied the application initially and on reconsideration. After hearings on November 16, 2020, and April 26, 2022, an Administrative Law Judge (ALJ) denied the application on November 22, 2022. The Appeals Council denied review on September 27, 2023.
William Y. moved for summary judgment, asking the court to remand the case for further proceedings. The Commissioner filed a cross-motion for summary judgment. William Y. challenged the ALJ's treatment of his lumbar radiculopathy, carpal tunnel syndrome, and neuropathy; the opinions of Maki Aoki, M.D., and Laura Jean Catlin, PsyD; his testimony; the residual functional capacity (RFC), meaning the work-related abilities the ALJ found he retained; the hypothetical given to the vocational expert; and conflicting estimates of available jobs.
Court's Analysis
Step-two impairments
At step two of the disability process, the ALJ determines whether the claimant has a medically severe impairment or combination of impairments. The court found that the ALJ improperly determined that William Y.'s lumbar radiculopathy and carpal tunnel syndrome were not severe based primarily on the absence of specific diagnostic examinations. The ALJ did not address neuropathy at that step and therefore gave no reasons for the court to review. The court also found it unclear whether the RFC accounted for the effects of these conditions on William Y.'s ability to walk. The court concluded that the ALJ erred in considering all three conditions at step two.
Medical opinions
The court found that the ALJ did not provide adequate support for rejecting Dr. Aoki's opinion that William Y. had substantial restrictions involving reaching, handling, fingering, sitting, standing, and walking. The court disagreed with the ALJ's treatment of the medical record, including the reasons concerning the timing of hand complaints, clinical observations, diagnostic studies, straight-leg-raise testing, William Y.'s ability to drive, and the effects of medication.
The court reached a different conclusion concerning Dr. Catlin's opinion. The ALJ found that opinion unpersuasive because its marked concentration limitations were inconsistent with Dr. Catlin's observations and testing, and because the opinion's statements about difficulty attending appointments and consistently engaging in treatment conflicted with evidence that William Y. regularly attended and made medical appointments. The court held that the ALJ adequately explained the rejection of Dr. Catlin's opinion with support from substantial evidence.
William Y.'s testimony and RFC
The court found that the ALJ did not specifically identify which parts of William Y.'s testimony were being rejected or explain how particular medical evidence undermined that testimony. A general summary of medical evidence supporting an RFC does not, by itself, provide the required clear and convincing reasons for rejecting symptom testimony. The court held that remand was necessary so the ALJ could determine the effect of William Y.'s testimony on the disability claim.
Because the ALJ's errors concerning step two, Dr. Aoki's opinion, and William Y.'s testimony could affect the RFC, the court also agreed that the RFC and the hypothetical presented to the vocational expert did not necessarily include all of William Y.'s limitations.
Job-number evidence
The vocational expert testified that a hypothetical person with the ALJ's RFC could perform work as a Bonder, Touch-Up Screener, and Table Worker, with a ten-percent reduction for the sit-stand option. William Y. submitted different estimates from Job Browser Pro to the Appeals Council. The court found that William Y. identified his methodology by using the same Dictionary of Occupational Titles job codes as the vocational expert. The court therefore concluded that the ALJ erred by failing to resolve the inconsistency between the job-number estimates.
Disposition
The court GRANTED William Y.'s motion for summary judgment and DENIED the Commissioner's cross-motion for summary judgment. It remanded the case for further proceedings. The court stated that the record did not make clear that the ALJ would be required to find William Y. disabled after properly evaluating the evidence. On remand, the ALJ must evaluate the evidence under applicable law and consistently with the order.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.