W.F. v. Commissioner of Social Security
- Nathanael Cousins
- 5:25-cv-03681
- U.S. District Court · Northern District of California
- 12
In W.F. v. Commissioner of Social Security, Judge Cousins reversed the benefits denial and sent the case back for further proceedings.
W.F.’s claim for disability benefits was sent back to the Social Security Administration for further consideration by the Administrative Law Judge; the court did not award benefits or decide the remaining arguments.
What happened
In W.F. v. Commissioner of Social Security, W.F. challenged an Administrative Law Judge’s denial of disability benefits beginning May 1, 2019. The Administrative Law Judge found that W.F. was not disabled and could perform past work and other jobs.
The court ruled that the Administrative Law Judge improperly evaluated medical opinions and medical evidence about W.F.’s mental impairments, especially when deciding whether they met the required medical listings. The court said the Administrative Law Judge did not adequately explain the opinions’ support and consistency and relied selectively on the record.
Judge Cousins reversed the Administrative Law Judge’s decision and remanded the matter for further consideration and proceedings. The court did not decide W.F.’s remaining arguments about testimony, work limitations, or vocational-expert evidence.
The detailed version
- W.F. v. Commissioner of Social Security · No. 5:25-cv-03681
- Nathanael Cousins
- Nov. 12, 2025
Background
W.F. sought disability insurance benefits under Title II and Title XVI, alleging disability beginning May 1, 2019. The claim was denied initially and on reconsideration. After a February 29, 2024 hearing, the Administrative Law Judge (ALJ) issued an unfavorable decision on May 21, 2024. The Appeals Council denied review, and W.F. appealed to the district court.
The ALJ found that W.F. had severe impairments including morbid obesity, bilateral inguinal hernia, generalized anxiety disorder, alcohol dependence in remission, and persistent depressive disorder. At the third step of the disability process, the ALJ found that W.F.’s impairments did not meet or medically equal the applicable listed impairments, including the listings for depressive and anxiety disorders. The ALJ determined that W.F. could perform medium work with a requirement to work independently and could perform past relevant work as a janitor and other jobs existing in significant numbers in the national economy.
Court’s Analysis
The court reviews a Social Security decision to determine whether it is supported by substantial evidence—evidence that a reasonable person would accept as adequate—or based on legal error. The court agreed with W.F. that the ALJ erred in evaluating the medical opinions and medical evidence concerning W.F.’s mental impairments.
The court found that the ALJ did not fully address the supportability and consistency of opinions from Drs. Dixit, Kresser, and Weiss. Supportability concerns the objective evidence and explanations supporting a medical opinion; consistency concerns whether the opinion agrees with other medical and nonmedical evidence. The court also found the ALJ’s treatment of Dr. Wiebe’s opinion unsupported by substantial evidence. The ALJ relied on one instance in which a therapist encouraged W.F. to continue looking for work, while failing to adequately account for extensive counseling and other records describing depression, anxiety, difficulty handling work and daily activities, memory problems, distractibility, and difficulties interacting with others.
The court also concluded that the ALJ’s findings about the paragraph B mental-functioning criteria were not supported by substantial evidence. Those criteria concern understanding and applying information, interacting with others, concentrating and maintaining pace, and adapting or managing oneself. The court cited evidence that could support greater limitations, including low memory-test scores, many missed or late therapy appointments, disorganized or distractible thought processes, difficulty staying on topic during the hearing, strained relationships, and inappropriate or impulsive behavior.
The court did not decide W.F.’s arguments about the evaluation of his testimony, residual functional capacity, or vocational-expert testimony. It explained that the arguments were unclear in part and that those issues could change after the ALJ properly reevaluated the medical opinions and the full record.
Disposition
The court did not order an immediate award of benefits. Instead, Judge Nathanael M. Cousins held that further administrative proceedings would be useful so the ALJ could properly weigh the medical opinions and reconsider the entire medical record. The court REVERSED the ALJ’s decision and REMANDED the matter for further consideration and proceedings.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.