Stanley v. O'Malley Commissioner of Social Security

Background

Sawanya Lashun Stanley appealed the Commissioner of Social Security’s denial of disability benefits under the Social Security Act. She first applied for disability insurance benefits and supplemental security income in 2015, alleging impairments including high blood pressure, fibromyalgia, chronic pain, muscle spasms, torn ligaments, nerve damage, depression, and anxiety. After earlier administrative and court proceedings, a new administrative law judge found Stanley disabled as of July 12, 2023, but not before that date.

The administrative law judge found that Stanley had ten severe impairments, including major depressive disorder, generalized anxiety disorder, post-traumatic stress disorder, chronic pain disorder, several shoulder and ankle conditions, and fibromyalgia. The judge determined that Stanley could perform a limited range of sedentary work before July 12, 2023, and that jobs existed in significant numbers that she could perform. The judge gave greater weight to a medical expert who had not treated Stanley and less weight to several treating and examining doctors who described more severe limitations.

The Court’s Analysis

The court held that the administrative law judge improperly evaluated the medical evidence concerning Stanley’s mental health. The judge discounted opinions from Dr. Margarita Orona and Roya Sakhai, who found marked and extreme limitations in concentration and in managing psychological symptoms, without providing legally sufficient reasons. The judge also gave only partial weight to Dr. Katherine Wiebe’s opinions describing marked work-related mental limitations and rejected Dr. Tonia Porchia’s opinion that Stanley met the requirements of certain mental-health disability listings.

The court also found errors in the evaluation of Stanley’s physical impairments. The administrative law judge discounted treating physician Omar Staples’s opinion that Stanley could perform no more than sedentary work, would likely be absent three times per month, and would be off task for more than one-third of each workday. The court concluded that the reasons given for rejecting that opinion—including Stanley’s work history and alleged inconsistencies with the medical record—were not supported by the required evidence.

The court further concluded that the administrative law judge improperly discounted Stanley’s reported symptoms and incorrectly found that her impairments did not meet or equal applicable disability listings. The Commissioner conceded the error concerning the listing determination and also conceded that the administrative law judge gave too much weight to earlier opinions from non-treating and non-examining state-agency doctors.

Remand for Benefits

The court applied the Ninth Circuit’s “credit-as-true” rule, which can require an immediate benefits award when the record is complete, the administrative law judge failed to give legally sufficient reasons for rejecting evidence, and accepting that evidence would require a finding of disability. The court found all three conditions satisfied. It determined that the record was fully developed, that further proceedings would serve no useful purpose, and that there was no serious doubt that Stanley was disabled.

The court found that, if the improperly rejected evidence were accepted, Stanley would meet the requirements of mental-health listings or otherwise could not perform work available in significant numbers. The court therefore remanded the matter to the administrative law judge for calculation and award of benefits, with a disability start date of April 2015.