Angel L. v. O’Malley (CD CA Nov. 12, 2024) - definition of medical source, lay evidence, subjective complaints

Angel L. v. O’Malley, Case No. 2:24-cv-04283-HDV-SHK (C.D. CA Nov. 12, 2024) (Order by U.S. District Judge Hernan D. Vera)

Briefs for purchase: Plaintiff’s Opening Brief, remand order

Topics addressed: 

• Definition of a medical source opinion

• Medical opinions – supportability

• Testimony of lay witnesses

• Subjective symptoms – mischaracterization of record

• Subjective complaints – improper focus on objective evidence

• Subjective complaints – interacting with others

• Subjective complaints – daily activities 

• Subjective symptoms – treatment regimen 

Ruling addressed:

Social Security Ruling 16-3p 

Issues briefed:

1)  The ALJ’s reasons for finding the opinion of Roberta Strangfeld Russell, Angel L.’s treating clinician, not persuasive, are not supported by substantial evidence.

2)  The ALJ failed to properly consider the lay evidence from Angel L.’s partner.

3)  The ALJ failed to properly evaluate Angel L.’s subjective complaints.

Court decision:
After Plaintiff briefed the merits, the Commissioner chose not to defend the ALJ’s decision and instead, sought a voluntary remand. The parties negotiated the remand terms and the court remanded for further proceedings.