Allen v. Kijakazi

CourtDistrict Court, S.D. California
DecidedMarch 9, 2022
Docket3:22-cv-00277
StatusUnknown

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

Bluebook
Allen v. Kijakazi, (S.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 KAREN A., Case No.: 3:22-cv-00277-AHG 12 Plaintiff, ORDER GRANTING MOTION FOR LEAVE TO PROCEED IN FORMA 13 v. PAUPERIS 14 KILOLO KIJAKAZI, Acting Commissioner of Social Security, [ECF No. 2] 15 Defendant. 16

17 On March 1, 2022, Plaintiff Karen A. (“Plaintiff”) brought this action against the 18 Commissioner of Social Security (“Defendant” or “Commissioner”), seeking judicial 19 review of the Commissioner’s final administrative decision denying her application for 20 Social Security Disability Insurance benefits and Social Security Supplemental Security 21 Income benefits for lack of disability on remand. ECF No. 1. Along with her Complaint, 22 Plaintiff also filed a Motion for Leave to Proceed in forma pauperis (“IFP”) under 28 23 U.S.C. § 1915. ECF No. 2. 24 I. LEGAL STANDARD 25 A motion to proceed IFP presents two issues for the Court’s consideration. First, the 26 Court must determine whether an applicant properly shows an inability to pay the $400 27 civil filing fee required by this Court. See 28 U.S.C. §§ 1914(a), 1915(a). To that end, an 28 1 applicant must also provide the Court with a signed affidavit “that includes a statement of 2 all assets[,] which shows inability to pay initial fees or give security.” CivLR 3.2(a). 3 Second, § 1915(e)(2)(B)(ii) requires the Court to evaluate whether an applicant’s complaint 4 sufficiently states a claim upon which relief may be granted. See Lopez v. Smith, 203 F.3d 5 1122, 1127 (9th Cir. 2000) (“1915(e) not only permits but requires a district court to 6 dismiss an in forma pauperis complaint that fails to state a claim.”). 7 II. DISCUSSION 8 A. Motion to Proceed IFP 9 An applicant need not be completely destitute to proceed IFP, but she must 10 adequately prove her indigence. Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 11 339–40 (1948). An adequate affidavit should “allege[] that the affiant cannot pay the court 12 costs and still afford the necessities of life.” Escobedo v. Applebees, 787 F.3d 1226, 1234 13 (9th Cir. 2015) (citing Adkins, 335 U.S. at 339). No exact formula is “set forth by statute, 14 regulation, or case law to determine when someone is poor enough to earn IFP status.” 15 Escobedo, 787 F.3d at 1235. Consequently, courts must evaluate IFP requests on a case- 16 by-case basis. See id. at 1235–36 (declining to implement a general benchmark of “twenty 17 percent of monthly household income”); see also Cal. Men’s Colony v. Rowland, 939 F.2d 18 854, 858 (9th Cir. 1991) (requiring that district courts evaluate indigency based upon 19 available facts and by exercise of their “sound discretion”), rev’d on other grounds, 506 20 U.S. 194 (1993); Venable v. Meyers, 500 F.2d 1215, 1216 (9th Cir. 1974). 21 An adequate affidavit should also state supporting facts “with some particularity, 22 definiteness and certainty.” United States v. McQuade, 647 F.2d 938, 940 (9th Cir. 1981) 23 (citing Jefferson v. United States, 277 F.2d 723, 725 (9th Cir. 1960)). The Court should not 24 grant IFP to an applicant who is “financially able, in whole or in material part, to pull h[er] 25 own oar.” Temple v. Ellerthorpe, 586 F. Supp. 848, 850 (D.R.I. 1984); see also Alvarez v. 26 Berryhill, No. 18cv2133-W-BGS, 2018 WL 6265021, at *1 (S.D. Cal. Oct. 1, 2018) (noting 27 that courts often reject IFP applications when applicants “can pay the filing fee with 28 acceptable sacrifice to other expenses”). Additionally, courts have discretion to make a 1 factual inquiry and to deny a motion to proceed IFP when the moving party is “unable, or 2 unwilling, to verify their poverty.” McQuade, 647 F.2d at 940. 3 Here, Plaintiff states in her affidavit that she receives $1,147.00 per month in 4 disability payments and $472.00 per month in food stamps. ECF No. 2 at 2. Her expected 5 monthly income barely covers her $966.00 in monthly expenses for utilities, food, laundry, 6 transportation, medication, and hotel stays. Id. at 4–5. She has $4,011.00 in her checking 7 account. Id. at 2. She explains that “the $3,441.60 in my account was deposited this month 8 from Social Security as a retro-active payment. The remaining balance is my monthly 9 payment from SSA.” Id. at 5. Plaintiff represents to the Court that she has been homeless 10 since December 3, 2013. Id. at 5. Plaintiff has no other source of income or valuable assets. 11 Id. at 1–5. Considering the information in the affidavit, the Court finds that Plaintiff has 12 sufficiently shown an inability to pay the $400 filing fee under § 1915(a). 13 B. Screening under 28 U.S.C. 1915(e) 14 As discussed above, every complaint filed pursuant to the IFP provisions of 28 15 U.S.C. § 1915 is subject to a mandatory screening by the Court under Section 16 1915(e)(2)(B). Lopez, 203 F.3d at 1127. Under that subprovision, the Court must dismiss 17 complaints that are frivolous or malicious, fail to state a claim on which relief may be 18 granted, or seek monetary relief from defendants who are immune from such relief. See 28 19 U.S.C. § 1915(e)(2)(B). Social Security appeals are not exempt from this screening 20 requirement. See Hoagland v. Astrue, No. 1:12-cv-00973-SMS, 2012 WL 2521753, at *1 21 (E.D. Cal. June 28, 2012) (“Screening is required even if the plaintiff pursues an appeal of 22 right, such as an appeal of the Commissioner’s denial of social security disability benefits 23 [under 42 U.S.C. 405(g)].”); see also Calhoun v. Stahl, 254 F.3d 845, 845 (9th Cir. 2001) 24 (affirming that “the provisions of 28 U.S.C. § 1915(e)(2)(B) are not limited to prisoners”); 25 Lopez, 203 F.3d at 1129. 26 Rule 8 sets forth the federal pleading standard used to determine whether a complaint 27 states a claim upon which relief may be granted. FED. R. CIV. P. 8; see also Ashcroft v. 28 Iqbal, 556 U.S. 662, 678–79 (2009) (“[A] complaint must contain a “short and plain 1 statement of the claim showing that the pleader is entitled to relief.”); Bell Atlantic Corp. 2 v. Twombly, 550 U.S. 544, 555 (2007) (noting that “detailed factual allegations” are not 3 required, but a plaintiff must provide “more than labels and conclusions, and a formulaic 4 recitation of the elements of a cause of action” to justify relief). A proper pleading “does 5 not require detailed factual allegations, but it demands more than an unadorned, the- 6 defendant-unlawfully-harmed-me accusation. A pleading that offers labels and conclusions 7 . . . will not do.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Adkins v. E. I. DuPont De Nemours & Co.
335 U.S. 331 (Supreme Court, 1948)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
New Hampshire Hemp Council, Inc. v. Marshall
203 F.3d 1 (First Circuit, 2000)
Jesse J. Calhoun v. Donald N. Stahl James Brazelton
254 F.3d 845 (Ninth Circuit, 2001)
Temple v. Ellerthorpe
586 F. Supp. 848 (D. Rhode Island, 1984)
Maria Escobedo v. Apple American Group
787 F.3d 1226 (Ninth Circuit, 2015)
Chemung Canal Trust Co. v. Sovran Bank/Maryland
939 F.2d 12 (Second Circuit, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
Allen v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-kijakazi-casd-2022.