Ami v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedSeptember 20, 2023
Docket2:22-cv-01202
StatusUnknown

This text of Ami v. Commissioner of Social Security Administration (Ami 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
Ami v. Commissioner of Social Security Administration, (D. Ariz. 2023).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Craig A. Ami, No.2:22-CV-01202-SMB Plaintiff, 10 ORDER v. 11 Commissioner of Social Security 12 Administration,

13 Defendant.

14 At issue is the denial of Plaintiff Craig A. Ami’s Application for Social Security 15 Disability Insurance (“SSDI”) benefits by the Social Security Administration (“SSA”) 16 under the Social Security Act (the “Act”). Plaintiff filed a Complaint, (Doc. 1), and an 17 Opening Brief, (Doc. 10), seeking judicial review of that denial. Defendant SSA filed an 18 Answering Brief, (Doc. 11), to which Plaintiff replied, (Doc. 12). The Court has reviewed 19 the parties’ briefs, the Administrative Record, (Doc. 8), and the Administrative Law 20 Judge’s (“ALJ’s”) decision, (Doc. 8-3 at 29–42), and will affirm the ALJ’s decision for the 21 reasons addressed herein. 22 I. BACKGROUND 23 Plaintiff filed an Application for SSDI benefits in June of 2019, alleging a disability 24 beginning in January of 2017. (Doc. 8-8 at 12–37.) Plaintiff’s claim was initially denied 25 in July of 2019. (Doc. 8-3 at 32.) A hearing was held before ALJ Sally Reason on January 26 11, 2021. (Id. at 42.) After considering the medical evidence and opinions, the ALJ 27 determined that Plaintiff suffered from severe impairments including obesity and lumbar 28 degenerative disk disease. (Id. at 35.) However, the ALJ concluded that, despite these 1 impairments, Plaintiff had the residual functional capacity (“RFC”) to perform light work 2 as defined in 20 CFR 404.1567(b). (Id. at 38.) Consequently, Plaintiff’s Application was 3 again denied by the ALJ on January 22, 2021. (Id. at 42.) Thereafter, the Appeals Council 4 denied Plaintiff’s Request for Review of the ALJ’s decision—making it the final decision 5 of the SSA Commissioner (the “Commissioner”)—and this appeal followed. (Doc. 1.) 6 II. LEGAL STANDARDS 7 An ALJ’s factual findings “shall be conclusive if supported by substantial 8 evidence.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). The Court may set aside 9 the Commissioner’s disability determination only if it is not supported by substantial 10 evidence or is based on legal error. Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007). 11 Substantial evidence is relevant evidence that a reasonable person might accept as adequate 12 to support a conclusion considering the record as a whole. Id. Generally, “[w]here the 13 evidence is susceptible to more than one rational interpretation, one of which supports the 14 ALJ’s decision, the ALJ’s conclusion must be upheld.” Thomas v. Barnhart, 278 F.3d 947, 15 954 (9th Cir. 2002). In determining whether to reverse an ALJ’s decision, the district court 16 reviews only those issues raised by the party challenging the decision. See Lewis v. Apfel, 17 236 F.3d 503, 517 n.13 (9th Cir. 2001). 18 III. DISCUSSION 19 Plaintiff argues that the ALJ committed materially harmful error in evaluating 20 Plaintiff’s symptom testimony and failing to provide a significant number of jobs that 21 match Plaintiff’s RFC. (Doc. 10.) The Commissioner argues that the ALJ’s opinion is 22 supported by substantial evidence and contains no legal error. (Doc. 11.) The Court has 23 reviewed the medical and administrative records and agrees with the Commissioner for the 24 following reasons. 25 A. Plaintiff’s Symptom Testimony 26 An ALJ performs a two-step analysis to evaluate a claimant’s testimony regarding 27 pain and symptoms. Garrison v. Colvin, 759 F.3d 995, 1014 (9th Cir. 2014). First, the 28 ALJ evaluates whether the claimant has presented objective medical evidence of an 1 impairment that “could reasonably be expected to produce the pain or symptoms alleged.” 2 Lingenfelter v. Astrue, 504 F.3d 1028, 1035–36 (9th Cir. 2007) (quoting Bunnell v. 3 Sullivan, 947 F.2d 341, 344 (9th Cir. 1991)) (internal quotation marks omitted). Second, 4 absent evidence of malingering, an ALJ may only discount a claimant’s allegations for 5 reasons that are “specific, clear and convincing” and supported by substantial evidence. 6 Molina v. Astrue, 674 F.3d 1104, 1112 (9th Cir. 2012). 7 “[T]he ALJ must specifically identify the testimony she or he finds not to be credible 8 and must explain what evidence undermines the testimony.” Holohan v. Massanari, 246 9 F.3d 1195, 1208 (9th Cir. 2001). General findings are insufficient. Id. “Although the 10 ALJ’s analysis need not be extensive, the ALJ must provide some reasoning in order for 11 [the Court] to meaningfully determine whether the ALJ’s conclusions were supported by 12 substantial evidence.” Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1103 (9th 13 Cir. 2014). “[T]he ALJ may consider inconsistencies either in the claimant’s testimony or 14 between the testimony and the claimant’s conduct.” Molina, 674 F.3d at 1112. For 15 instance, the ALJ may consider “whether the claimant engages in daily activities 16 inconsistent with the alleged symptoms.” Id. (quoting Lingenfelter, 504 F.3d at 1040). 17 Plaintiff argues the ALJ committed materially harmful error by rejecting Plaintiff’s 18 testimony when limitations stemming from his symptoms would otherwise preclude his 19 ability to work. (Doc. 10 at 9–14.) Plaintiff further argues that the ALJ did not clearly 20 explain how his testimony is inconsistent with other parts of the record. (Id.) The 21 Commissioner argues the ALJ’s discounting of Ami’s testimony is supported by 22 substantial evidence. (Doc. 11.) The Commissioner further argues the ALJ gave valid 23 reasons for discounting Plaintiff symptom testimony including that his treatment is 24 conservative, he had a gap in his work history prior to the alleged disability, he is able to 25 perform daily tasks, and his impairments can be successfully mitigated by prescribed 26 treatment. (Id.) 27 Here, Plaintiff testified that he needed constant breaks at his las job due to pain, can 28 “barely stand an hour,” but is able to live alone and cited no problems being able to perform 1 daily living activities. (Doc.10 at 7, Doc. 8-3 at 39.) The ALJ, although noting that 2 Plaintiff likely has symptoms that align with his diagnosed impairment, found that Plaintiff 3 has “generally been treated with conservative methods including various . . . injections, 4 physical therapy and medications” and that none of these medications lead to symptoms 5 that otherwise inhibit his ability to work. (Doc. 8-3 at 39.) The ALJ also discounted 6 Plaintiff’s symptom testimony because medical records show a gap in treatment, which 7 undermines the severity he alleges. (Doc. 8-3 at 40.) The Court agrees with the 8 Commissioner that the ALJ gave specific reasons for finding Plaintiff’s testimony is not 9 credible—including the gap in treatment, the absence of a clinical disability finding, and 10 Plaintiff’s self-professed ability to perform daily tasks. (Doc. 8-3 at 39–40.); see 11 Tommasetti v. Astrue, 533 F.3d 1035, 1039 (9th Cir.

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Related

Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
United States v. Ralph R. Ross
9 F.3d 1182 (Seventh Circuit, 1993)
Tommasetti v. Astrue
533 F.3d 1035 (Ninth Circuit, 2008)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Lingenfelter v. Astrue
504 F.3d 1028 (Ninth Circuit, 2007)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Maria Gutierrez v. Carolyn Colvin
844 F.3d 804 (Ninth Circuit, 2016)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Bunnell v. Sullivan
947 F.2d 341 (Ninth Circuit, 1991)

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Ami v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ami-v-commissioner-of-social-security-administration-azd-2023.