Agnes W. v. O'Malley
- Alex Tse
- 3:24-cv-01958
- U.S. District Court · Northern District of California
- 8
In Agnes W. v. Bisignano, Judge Tse affirmed the denial of Agnes W.’s disability benefits after finding the administrative law judge’s decision supported by substantial evidence.
Agnes W.’s claim for disability benefits was affected because the court affirmed the Commissioner’s denial of benefits.
What happened
Agnes W. v. Bisignano concerns Agnes W.’s challenge to the denial of her disability benefits. She asked the court to reverse the decision and send the matter back for further proceedings, while the Commissioner asked the court to affirm it.
Agnes W. argued that the administrative law judge improperly evaluated medical opinions and improperly discounted her testimony about the severity of her shoulder problems. The court found that the medical evidence, treatment history, reported improvements, and examination findings supported the administrative law judge’s conclusions.
Judge Tse affirmed the Commissioner’s decision. The court acknowledged an error in describing which shoulder showed evidence of a rim tear, but found that the error did not require sending the case back because substantial evidence independently supported the decision.
The detailed version
- Agnes W. v. O'Malley · No. 3:24-cv-01958
- Alex Tse
- Sept. 29, 2025
Background
Agnes W. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s decision denying her claim for disability benefits. Agnes W. moved for reversal and remand, and the Commissioner moved to affirm the administrative law judge’s decision. The opinion states that Frank J. Bisignano was substituted for Martin J. O’Malley under Federal Rule of Civil Procedure 25(d).
Agnes W. raised two issues: whether the administrative law judge failed to evaluate medical-opinion evidence as required by 20 C.F.R. § 404.1520c, and whether the finding about the credibility or consistency of her testimony was supported by the record.
Medical-opinion evidence
The administrative law judge found the prior administrative medical findings of Dr. W. Jackson and Dr. K. Vu generally persuasive, but found the opinions of Dr. Matthew Kale Wedemeyer and Katie Knott, PA-C, unpersuasive. The opinions differed in part over lifting restrictions: Drs. Jackson and Vu concluded that Agnes W. could occasionally lift up to 20 pounds, while Dr. Wedemeyer concluded that she could lift only 5 pounds with either hand.
The court held that Agnes W. had not shown a basis for setting aside the evaluation of Dr. Wedemeyer’s opinions. The court also independently found that the evaluation was supported by substantial evidence, meaning enough relevant evidence that a reasonable decision-maker could rely on. The record showed improved symptoms after treatment, including significant or near-total relief from injections, improved or full shoulder movement in some examinations, and good or improved upper-extremity strength. The court also found support for the administrative law judge’s conclusion that the limitations were inconsistent with conservative treatment and relatively intact daily activities.
The court rejected Agnes W.’s argument that Drs. Jackson and Vu had not reviewed the May 20, 2021, magnetic resonance imaging scan concerning her left shoulder. The court found that both doctors had reviewed records describing that scan and had considered shoulder problems. The court agreed that the doctors mistakenly referred to a rim tear in the left shoulder when the scan showed that finding in the right shoulder. But the court concluded that this misstatement did not require remand because the administrative law judge still recognized severe impairments in both shoulders and otherwise relied on opinions that were well explained, supported by objective findings, and consistent with the record.
Testimony about symptoms
Agnes W. argued that her daily activities did not conflict with her testimony and therefore could not support discounting her statements. The court focused on other reasons given by the administrative law judge. Those reasons included medical findings showing better shoulder mobility than Agnes W. described, improvement after injections and other conservative treatments, and treatment records documenting reduced pain and improved function.
The court stated that even if relying on daily activities had been an error, the decision remained supported by the objective medical evidence and the effectiveness of conservative treatment. The court concluded that the administrative law judge gave specific, clear, and convincing reasons for finding that Agnes W.’s statements about the severity of her symptoms were not entirely consistent with the medical and other evidence.
Disposition
Judge Alex Tse affirmed the Commissioner’s decision denying Agnes W.’s disability benefits. The court did not remand the matter.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.