Ain v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedSeptember 30, 2024
Docket2:24-cv-00008
StatusUnknown

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

Bluebook
Ain v. Commissioner of Social Security Administration, (D. Ariz. 2024).

Opinion

6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 Sara Elise Ain, No. CV-24-00008-DLR (ESW) 9

10 Plaintiff, REPORT AND RECOMMENDATION 11 v. 12 Commissioner of the Social Security 13 Administration, 14 Defendant. 15

17 TO THE HONORABLE DOUGLAS L. RAYES, SENIOR UNITED STATES 18 DISTRICT JUDGE: 19 Pending before the Court is Sara Elise Ain’s (“Plaintiff”) appeal of the Social 20 Security Administration’s (“Social Security”) denial of her application for disability 21 insurance benefits. The Court has jurisdiction to decide Plaintiff’s appeal pursuant to 42 22 U.S.C. § 405(g). Under 42 U.S.C. § 405(g), the Court has the power to enter, based upon 23 the pleadings and transcript of the record, a judgment affirming, modifying, or reversing 24 the decision of the Commissioner of Social Security, with or without remanding the case 25 for a rehearing. 26 After reviewing the Administrative Record (“A.R.”) and the parties’ briefing (Docs. 27 19, 21, 22), the undersigned finds that the Administrative Law Judge’s (“ALJ”) decision 28 contains harmful legal error. For the reasons explained in Section II below, it is 1 recommended that the decision be reversed and the case remanded to the Commissioner of 2 Social Security for further proceedings. 3 I. LEGAL STANDARDS 4 A. Disability Analysis: Five-Step Evaluation 5 The Social Security Act (the “Act”) provides for disability insurance benefits to 6 those who have contributed to the Social Security program and who suffer from a physical 7 or mental disability. 42 U.S.C. § 423(a)(1). The Act also provides for supplemental security 8 income to certain individuals who are aged 65 or older, blind, or disabled and have limited 9 income. 42 U.S.C. § 1382. To be eligible for benefits based on an alleged disability, the 10 claimant must show that he or she suffers from a medically determinable physical or mental 11 impairment that prohibits him or her from engaging in any substantial gainful activity. 42 12 U.S.C. § 423(d)(1)(A); 42 U.S.C. § 1382c(A)(3)(A). The claimant must also show that the 13 impairment is expected to cause death or last for a continuous period of at least 12 months. 14 Id. 15 To decide if a claimant is entitled to Social Security disability benefits, an ALJ 16 conducts an analysis consisting of five questions, which are considered in sequential steps. 17 20 C.F.R. §§ 404.1520(a), 416.920(a). The claimant has the burden of proof regarding the 18 first four steps:1 19 Step One: Is the claimant engaged in “substantial gainful 20 activity”? If so, the analysis ends and disability benefits are denied. Otherwise, the ALJ proceeds to step two. 21 Step Two: Does the claimant have a medically severe 22 impairment or combination of impairments? A severe 23 impairment is one which significantly limits the claimant’s 24 physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant does not have a 25 severe impairment or combination of impairments, disability 26 27

28 1 Parra v. Astrue, 481 F.3d 742,746 (9th Cir. 2007). 1 benefits are denied at this step. Otherwise, the ALJ proceeds 2 to step three. 3 Step Three: Is the impairment equivalent to one of a number of listed impairments that the Commissioner acknowledges are 4 so severe as to preclude substantial gainful activity? 20 C.F.R. 5 §§ 404.1520(d), 416.920(d). If the impairment meets or equals 6 one of the listed impairments, the claimant is conclusively presumed to be disabled. If the impairment is not one that is 7 presumed to be disabling, the ALJ proceeds to the fourth step 8 of the analysis. 9 Step Four: Does the impairment prevent the claimant from 10 performing work which the claimant performed in the past? If 11 not, the claimant is “not disabled” and disability benefits are denied without continuing the analysis. 20 C.F.R. §§ 12 404.1520(f), 416.920(f). Otherwise, the ALJ proceeds to the 13 last step. 14 If the analysis proceeds to the final question, the burden of proof shifts to the 15 Commissioner:2 16 Step Five: Can the claimant perform other work in the national 17 economy in light of his or her age, education, and work experience? The claimant is entitled to disability benefits only 18 if he or she is unable to perform other work. 20 C.F.R. §§ 19 404.1520(g), 416.920(g). Social Security is responsible for providing evidence that demonstrates that other work exists in 20 significant numbers in the national economy that the claimant 21 can do, given the claimant’s residual functional capacity, age, education, and work experience. Id. 22 B. Standard of Review Applicable to ALJ’s Determination 23 The Court must affirm an ALJ’s decision if it is supported by substantial evidence 24 and is based on correct legal standards. Molina v. Astrue, 674 F.3d 1104, 1110 (9th Cir. 25 2012); Marcia v. Sullivan, 900 F.2d 172, 174 (9th Cir. 1990). Although “substantial 26 evidence” is less than a preponderance, it is more than a “mere scintilla.” Richardson v. 27

28 2 Parra, 481 F.3d at 746. 1 Perales, 402 U.S. 389, 401 (1971) (quoting Consolidated Edison v. NLRB, 305 U.S. 197, 2 229 (1938)). It means such relevant evidence as a reasonable mind might accept as 3 adequate to support a conclusion. Id. 4 In determining whether substantial evidence supports the ALJ’s decision, the Court 5 considers the record as a whole, weighing both the evidence that supports and detracts from 6 the ALJ’s conclusions. Reddick v. Chater, 157 F.3d 715, 720 (9th Cir. 1998); Tylitzki v. 7 Shalala, 999 F.2d 1411, 1413 (9th Cir. 1993). If there is sufficient evidence to support the 8 ALJ’s determination, the Court cannot substitute its own determination. See Morgan v. 9 Comm’r of the Social Sec. Admin., 169 F.3d 595, 599 (9th Cir. 1999) (“Where the evidence 10 is susceptible to more than one rational interpretation, it is the ALJ’s conclusion that must 11 be upheld.”); Magallanes v. Bowen, 881 F.2d 747, 750 (9th Cir. 1989).

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Ain v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ain-v-commissioner-of-social-security-administration-azd-2024.