Abrahamson v. Social Security

CourtDistrict Court, E.D. Washington
DecidedApril 28, 2023
Docket2:22-cv-00202
StatusUnknown

This text of Abrahamson v. Social Security (Abrahamson v. Social Security) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abrahamson v. Social Security, (E.D. Wash. 2023).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Apr 28, 2023 SEAN F. MCAVOY, CLERK 3 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 MYRNA A., NO: 2:22-CV-0202-TOR 8 Plaintiff, ORDER DENYING PLAINTIFF’S 9 v. BRIEF AND GRANTING DEFENDANT’S BRIEF 10 KILOLO KIJAKAZI, Acting Commissioner of Social Security, 11 Defendant. 12

13 BEFORE THE COURT are the parties’ briefs seeking judgment in this case. 14 ECF Nos. 6, 10, and 11. The briefing was submitted for consideration without oral 15 argument. The Court has reviewed the administrative record and the parties’ 16 completed briefing and is fully informed. For the reasons discussed below, 17 Plaintiff’s request for remand, ECF No. 6, is DENIED, and Defendant’s request for 18 affirmance, ECF No. 10, is GRANTED. 19 // 20 // 1 JURISDICTION 2 The Court has jurisdiction over this case pursuant to 42 U.S.C. § 405(g).

3 STANDARD OF REVIEW 4 A district court’s review of a final decision of the Commissioner of Social 5 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is

6 limited: the Commissioner’s decision will be disturbed “only if it is not supported 7 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 8 1158 (9th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence” means 9 relevant evidence that “a reasonable mind might accept as adequate to support a

10 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, 11 substantial evidence equates to “more than a mere scintilla[,] but less than a 12 preponderance.” Id. In determining whether this standard has been satisfied, a

13 reviewing court must consider the entire record as a whole rather than searching 14 for supporting evidence in isolation. Id. 15 In reviewing a denial of benefits, a district court may not substitute its 16 judgment for that of the Commissioner. If the evidence in the record “is

17 susceptible to more than one rational interpretation, [the court] must uphold the 18 ALJ’s findings if they are supported by inferences reasonably drawn from the 19 record.” Molina v. Astrue, 674 F.3d 1104, 1111 (9th Cir. 2012) (citation omitted).

20 Further, a district court “may not reverse an ALJ’s decision on account of an error 1 that is harmless.” Id. An error is harmless “where it is inconsequential to the 2 [ALJ’s] ultimate nondisability determination.” Id. at 1115 (quotation and citation

3 omitted). The party appealing the ALJ’s decision generally bears the burden of 4 establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 396, 409–10 (2009). 5 FIVE-STEP SEQUENTIAL EVALUATION PROCESS

6 A claimant must satisfy two conditions to be considered “disabled” within 7 the meaning of the Social Security Act. First, the claimant must be “unable to 8 engage in any substantial gainful activity by reason of any medically determinable 9 physical or mental impairment which can be expected to result in death or which

10 has lasted or can be expected to last for a continuous period of not less than twelve 11 months.” 42 U.S.C. § 423(d)(1)(A). Second, the claimant’s impairment must be 12 “of such severity that he is not only unable to do his previous work[,] but cannot,

13 considering his age, education, and work experience, engage in any other kind of 14 substantial gainful work which exists in the national economy.” 42 U.S.C. 15 § 423(d)(2)(A). 16 The Commissioner has established a five-step sequential analysis to

17 determine whether a claimant satisfies the above criteria. See 20 C.F.R. § 18 404.1520(a)(4)(i)–(v). At step one, the Commissioner considers the claimant’s 19 work activity. 20 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in

20 “substantial gainful activity,” the Commissioner must find that the claimant is not 1 disabled. 20 C.F.R. § 404.1520(b). 2 If the claimant is not engaged in substantial gainful activities, the analysis

3 proceeds to step two. At this step, the Commissioner considers the severity of the 4 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers 5 from “any impairment or combination of impairments which significantly limits

6 [his or her] physical or mental ability to do basic work activities,” the analysis 7 proceeds to step three. 20 C.F.R. § 404.1520(c). If the claimant’s impairment 8 does not satisfy this severity threshold, however, the Commissioner must find that 9 the claimant is not disabled. Id.

10 At step three, the Commissioner compares the claimant’s impairment to 11 several impairments recognized by the Commissioner to be so severe as to 12 preclude a person from engaging in substantial gainful activity. 20 C.F.R. §

13 404.1520(a)(4)(iii). If the impairment is as severe, or more severe than one of the 14 enumerated impairments, the Commissioner must find the claimant disabled and 15 award benefits. 20 C.F.R. § 404.1520(d). 16 If the severity of the claimant’s impairment does meet or exceed the severity

17 of the enumerated impairments, the Commissioner must pause to assess the 18 claimant’s “residual functional capacity.” Residual functional capacity (“RFC”), 19 defined generally as the claimant’s ability to perform physical and mental work

20 activities on a sustained basis despite his or her limitations (20 C.F.R. § 1 404.1545(a)(1)), is relevant to both the fourth and fifth steps of the analysis. 2 At step four, the Commissioner considers whether, in view of the claimant’s

3 RFC, the claimant is capable of performing work that he or she has performed in 4 the past (“past relevant work”). 20 C.F.R. § 404.1520(a)(4)(iv). If the claimant is 5 capable of performing past relevant work, the Commissioner must find that the

6 claimant is not disabled. 20 C.F.R. § 404.1520(f). If the claimant is incapable of 7 performing such work, the analysis proceeds to step five. 8 At step five, the Commissioner considers whether, in view of the claimant’s 9 RFC, the claimant is capable of performing other work in the national economy.

10 20 C.F.R. § 404.1520(a)(4)(v).

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Abrahamson v. Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abrahamson-v-social-security-waed-2023.