Alexander v. Kijakazi

CourtDistrict Court, E.D. Washington
DecidedSeptember 12, 2023
Docket4:22-cv-05084
StatusUnknown

This text of Alexander v. Kijakazi (Alexander v. Kijakazi) 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
Alexander v. Kijakazi, (E.D. Wash. 2023).

Opinion

1 FILED IN THE U.S. DISTRICT COURT 2 EASTERN DISTRICT OF WASHINGTON Sep 12, 2023 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 MARGARET A.,1 No. 4:22-cv-05084-MKD

8 Plaintiff, ORDER REVERSING AND REMANDING DECISION 9 v. OF COMMISSIONER

10 KILOLO KIJAKAZI, ACTING ECF Nos. 12, 13 COMMISSIONER OF SOCIAL 11 SECURITY,

12 Defendant. 13 Before the Court are the parties’ briefs. ECF Nos. 12, 13. The Court, 14 having reviewed the administrative record and the parties’ briefing, is fully 15 informed. For the reasons discussed below, the Court reverses the 16 Commissioner’s decision and remands the case. 17

18 1 To protect the privacy of plaintiffs in social security cases, the undersigned 19 identifies them by only their first names and the initial of their last names. See 20 LCivR 5.2(c). 2 1 JURISDICTION 2 The Court has jurisdiction over this case pursuant to 42 U.S.C. §

3 1383(c)(3). 4 STANDARD OF REVIEW 5 A district court’s review of a final decision of the Commissioner of Social

6 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) 7 is limited; the Commissioner’s decision will be disturbed “only if it is not 8 supported by substantial evidence or is based on legal error.” Hill v. Astrue, 698 9 F.3d 1153, 1158 (9th Cir. 2012). “Substantial evidence” means “relevant

10 evidence that a reasonable mind might accept as adequate to support a 11 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, 12 substantial evidence equates to “more than a mere scintilla[,] but less than a

13 preponderance.” Id. (quotation and citation omitted). In determining whether the 14 standard has been satisfied, a reviewing court must consider the entire record as a 15 whole rather than searching for supporting evidence in isolation. Id. 16 In reviewing a denial of benefits, a district court may not substitute its

17 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 18 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than 19 one rational interpretation, [the court] must uphold the ALJ’s findings if they are

20 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 2 1 674 F.3d 1104, 1111 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. 2 §§ 404.1502(a), 416.902(a). Further, a district court “may not reverse an ALJ’s

3 decision on account of an error that is harmless.” Id. An error is harmless 4 “where it is inconsequential to the [ALJ’s] ultimate nondisability determination.” 5 Id. at 1115 (quotation and citation omitted). The party appealing the ALJ’s

6 decision generally bears the burden of establishing that it was harmed. Shinseki 7 v. Sanders, 556 U.S. 396, 409-10 (2009). 8 FIVE-STEP EVALUATION PROCESS 9 A claimant must satisfy two conditions to be considered “disabled” within

10 the meaning of the Social Security Act. First, the claimant must be “unable to 11 engage in any substantial gainful activity by reason of any medically 12 determinable physical or mental impairment which can be expected to result in

13 death or which has lasted or can be expected to last for a continuous period of not 14 less than twelve months.” 42 U.S.C. § 1382c(a)(3)(A). Second, the claimant’s 15 impairment must be “of such severity that he is not only unable to do his previous 16 work[,] but cannot, considering his age, education, and work experience, engage

17 in any other kind of substantial gainful work which exists in the national 18 economy.” 42 U.S.C. § 1382c(a)(3)(B). 19 The Commissioner has established a five-step sequential analysis to

20 determine whether a claimant satisfies the above criteria. See 20 C.F.R. § 2 1 416.920(a)(4)(i)-(v). At step one, the Commissioner considers the claimant’s 2 work activity. 20 C.F.R. § 416.920(a)(4)(i). If the claimant is engaged in

3 “substantial gainful activity,” the Commissioner must find that the claimant is not 4 disabled. 20 C.F.R. § 416.920(b). 5 If the claimant is not engaged in substantial gainful activity, the analysis

6 proceeds to step two. At this step, the Commissioner considers the severity of the 7 claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers 8 from “any impairment or combination of impairments which significantly limits 9 [his or her] physical or mental ability to do basic work activities,” the analysis

10 proceeds to step three. 20 C.F.R. § 416.920(c). If the claimant’s impairment 11 does not satisfy this severity threshold, however, the Commissioner must find 12 that the claimant is not disabled. Id.

13 At step three, the Commissioner compares the claimant’s impairment to 14 severe impairments recognized by the Commissioner to be so severe as to 15 preclude a person from engaging in substantial gainful activity. 20 C.F.R. § 16 416.920(a)(4)(iii). If the impairment is as severe or more severe than one of the

17 enumerated impairments, the Commissioner must find the claimant disabled and 18 award benefits. 20 C.F.R. § 416.920(d). 19 If the severity of the claimant’s impairment does not meet or exceed the

20 severity of the enumerated impairments, the Commissioner must pause to assess 2 1 the claimant’s “residual functional capacity.” Residual functional capacity 2 (RFC), defined generally as the claimant’s ability to perform physical and mental

3 work activities on a sustained basis despite his or her limitations, 20 C.F.R. § 4 416.945(a)(1), is relevant to both the fourth and fifth steps of the analysis. 5 At step four, the Commissioner considers whether, in view of the

6 claimant’s RFC, the claimant is capable of performing work that he or she has 7 performed in the past (past relevant work). 20 C.F.R. § 416.920(a)(4)(iv). If the 8 claimant is capable of performing past relevant work, the Commissioner must 9 find that the claimant is not disabled. 20 C.F.R. § 416.920(f). If the claimant is

10 incapable of performing such work, the analysis proceeds to step five. 11 At step five, the Commissioner considers whether, in view of the 12 claimant’s RFC, the claimant is capable of performing other work in the national

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Alexander v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexander-v-kijakazi-waed-2023.