Roselia A. v. Colvin
- Jacquelyn Corley
- 3:24-cv-04997
- U.S. District Court · Northern District of California
- 12
In Roselia A. v. Colvin, Judge Corley reversed part of the benefits denial and sent the case back for further proceedings.
Roselia A., whose denial of Social Security disability benefits was reversed in part, and the Social Security proceedings that must be reconsidered by the ALJ.
What happened
In Roselia A. v. Colvin, Roselia A. asked the court to review the denial of her Social Security disability benefits. She alleged several physical conditions, including knee and spine problems, obesity, diabetes, and adrenal insufficiency.
The court upheld the finding that her adrenal insufficiency was not a severe impairment. But it found that the Administrative Law Judge did not properly evaluate Roselia A.’s pain testimony or Dr. Beltran’s opinion about her work limitations because the judge focused on supporting evidence while overlooking contrary evidence.
Judge Jacquelyn Corley reversed the Administrative Law Judge’s decision in part and remanded the case for further proceedings. The court did not order payment of benefits; it directed the Administrative Law Judge to reconsider the pain testimony and medical opinion using the full record.
The detailed version
- Roselia A. v. Colvin · No. 3:24-cv-04997
- Jacquelyn Corley
- Mar. 31, 2025
Background
Roselia A. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her application for disability insurance benefits. She alleged a disability onset date of September 4, 2020, and identified physical impairments including degenerative disc disease, osteoarthritis in both knees, obesity, hypertension, type II diabetes, mild anemia, mild obstructive sleep apnea, and adrenal insufficiency.
An Administrative Law Judge (ALJ) held a telephone hearing on September 13, 2023. Roselia A. testified with help from a Spanish-language interpreter, and a vocational expert also testified. On October 31, 2023, the ALJ found that she was not disabled. The Appeals Council denied review, after which Roselia A. filed this action. The parties submitted briefs rather than presenting oral argument.
Issues and Rulings
The court considered whether the ALJ erred by finding that Roselia A.’s secondary adrenal insufficiency was not a severe impairment, by rejecting her testimony about the severity of her symptoms, and by evaluating the medical evidence.
The court upheld the step-two finding concerning adrenal insufficiency. The ALJ found that the condition improved significantly after treatment with hydrocortisone and that Roselia A. completed that treatment in July 2023. The court concluded that substantial evidence supported the finding that the adrenal insufficiency was not severe. The court also concluded that Roselia A. had not provided medical evidence showing that the condition caused the other symptoms she identified or workplace limitations lasting at least 12 consecutive months.
The court rejected the ALJ’s reasons for discounting Roselia A.’s subjective pain testimony. Because the ALJ found that her medically determinable impairments could reasonably cause some of her symptoms and did not find evidence of malingering, the ALJ needed specific, clear, and convincing reasons supported by substantial evidence to reject her testimony about symptom severity. The court found that the ALJ improperly characterized the objective medical evidence as showing only minimal or mild problems, overlooked evidence of significant knee and spine conditions, failed to account for the effect of pain on her effort during a neurological examination, and selected supporting evidence while ignoring contradictory records. The court also found that the ALJ did not adequately consider why Roselia A. received limited treatment, including restrictions on further injections, insurance-related missed appointments, and continuing pain despite medication. The court further found that the ALJ improperly relied on activities of daily living and on one statement about why Roselia A. stopped working.
The court also held that substantial evidence did not support the ALJ’s evaluation of Dr. Joyce Beltran’s February 3, 2023 opinion. The ALJ found the opinion unpersuasive because it was not well supported by Dr. Beltran’s own findings and was inconsistent with the overall record. The court concluded that the ALJ overlooked medical notes documenting degenerative changes, chronic joint pain, difficulty remaining in one position, hand pain and numbness, reduced grip strength, and treatment for pain. The court also found that the ALJ focused on evidence consistent with the non-disability finding while ignoring evidence supporting Dr. Beltran’s lifting and postural limitations.
Harmless Error and Remedy
The court determined that these errors were not harmless because they went to the heart of the disability determination. The court stated that, if the evidence had been properly considered, an ALJ could reasonably have reached a different conclusion about Roselia A.’s ability to work. The court therefore did not decide Roselia A.’s remaining arguments concerning additional medical evidence submitted to the Appeals Council.
Roselia A. requested a remand for further proceedings in her reply brief. The court concluded that further proceedings were appropriate so the ALJ could fully consider her pain reports and Dr. Beltran’s findings in the context of the entire record.
Disposition
The court REVERSED the ALJ’s decision in part and REMANDED for further proceedings consistent with the order. It did not order payment of benefits. The order disposed of Docket Nos. 8 and 12.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.