Arnell v. Saul

CourtDistrict Court, D. Idaho
DecidedSeptember 29, 2022
Docket4:20-cv-00459
StatusUnknown

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

Bluebook
Arnell v. Saul, (D. Idaho 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

SARA LEN A., Case No.: 4:20-cv-00459-REP

Petitioner, MEMORANDUM DECISION AND ORDER vs.

COMMISSIONER OF SOCIAL SECURITY,

Respondent.

Pending is Petitioner Sara Len A.’s Petition for Review (Dkt. 1) and an accompanying Motion for Summary Judgment (Dkt. 32) appealing the Social Security Administration’s final decision finding her not disabled and denying her claim for disability benefits. See Pet. for Review (Dkt. 1). This action is brought pursuant to 42 U.S.C. § 405(g). Having carefully considered the record and otherwise being fully advised, the Court enters the following Memorandum Decision and Order. I. ADMINISTRATIVE PROCEEDINGS On February 18, 2018, Petitioner protectively filed a Title II application for a period of disability and disability insurance benefits, alleging disability beginning July 22, 2017. The claim was originally denied on April 2, 2018, and again on reconsideration on August 17, 2018. On August 29, 2018, Petitioner filed a Request for Hearing before an Administrative Law Judge (“ALJ”). On March 9, 2020, ALJ David Willis held a hearing in Pocatello, Idaho, at which time Petitioner, represented by then-attorney Todd Pingel, appeared and testified. Anne T. Arrington, an impartial vocational expert, also appeared and testified at the same hearing. On April 29, 2020, the ALJ issued a decision denying Petitioner’s claim, finding that she was not disabled within the meaning of the Social Security Act. Petitioner timely requested review from the Appeals Council. On September 1, 2020, the Appeals Council denied Petitioner’s Request for Review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Petitioner is now represented by Josephine Gerrard and Brad Parkinson and, having exhausted her administrative remedies, brings this case. She raises three points of error: (i)

proper judicial review is impossible because the transcript of the March 9, 2020 hearing is incomplete; (ii) the ALJ failed to address her mental impairments and limitations in several respects; and (iii) at step five of the sequential process, the ALJ failed to identify jobs consistent with her medical records. Pet.’s Brief at 12-21 (Dkt. 32).1 Petitioner requests that the Court either reverse the ALJ’s decision and find that she is entitled to benefits, or remand the case for further proceedings and award attorneys’ fees. Id. at 21-22. II. STANDARD OF REVIEW To be upheld, the Commissioner’s decision must be supported by substantial evidence and based on proper legal standards. 42 U.S.C. § 405(g); Trevizo v. Berryhill, 871 F.3d 664 (9th

Cir. 2017). Findings as to any question of fact, if supported by substantial evidence, are conclusive. See 42 U.S.C. § 405(g). If there is substantial evidence to support the ALJ’s factual decisions, they must be upheld, even when there is conflicting evidence. See Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1098 (9th Cir. 2014). “Substantial evidence” is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971); Ludwig v.

1 Petitioner rhetorically posits another possible point of error in her briefing: “Did the ALJ address [her] pain and migraines in the residual functional capacity finding?” Pet.’s Brief at 12 (Dkt. 32) (listed as one of the several “issues”). However, this argument was never actually developed in the balance of Petitioner’s opening brief or her reply brief. Likewise, Respondent never confronted such an argument. The Court, therefore, does not consider this argument as part of this action. Astrue, 681 F.3d 1047, 1051 (9th Cir. 2012). The standard requires more than a scintilla but less than a preponderance. Trevizo, 871 F.3d at 674. It “does not mean a large or considerable amount of evidence.” Pierce v. Underwood, 487 U.S. 552, 565 (1988). With respect to questions of fact, the Court is to review the record as a whole to decide whether it contains evidence that would allow a reasonable mind to accept the conclusions of the

ALJ. Richardson, 402 U.S. at 401; see also Ludwig, 681 F.3d at 1051. The ALJ is responsible for determining credibility, resolving conflicts in medical testimony, and resolving ambiguities. Treichler, 775 F.3d at 1098. Where the evidence is susceptible to more than one rational interpretation, the reviewing court must uphold the ALJ’s findings if they are supported by inferences reasonably drawn from the record. Ludwig, 681 F.3d at 1051. In such cases, the reviewing court may not substitute its judgment or interpretation of the record for that of the ALJ. Batson v. Comm’r of Soc. Sec., 359 F.3d 1190, 1196 (9th Cir. 2004). The decision must be based on proper legal standards and will be reversed for legal error. Zavalin v. Colvin, 778 F.3d 842, 845 (9th Cir. 2015). Considerable weight is given to the ALJ’s

construction of the Social Security Act. See Vernoff v. Astrue, 568 F.3d 1102, 1105 (9th Cir. 2009). However, this Court “will not rubber-stamp an administrative decision that is inconsistent with the statutory mandate or that frustrates the congressional purpose underlying the statute.” Smith v. Heckler, 820 F.2d 1093, 1094 (9th Cir. 1987). III. DISCUSSION A. Sequential Process In evaluating the evidence presented at an administrative hearing, the ALJ must follow a sequential process in determining whether a person is disabled in general (20 C.F.R. §§ 404.1520, 416.920) – or continues to be disabled (20 C.F.R. §§ 404.1594, 416.994) – within the meaning of the Social Security Act. The first step requires the ALJ to determine whether the claimant is engaged in substantial gainful activity (“SGA”). 20 C.F.R. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). SGA is work activity that is both substantial and gainful. 20 C.F.R. §§ 404.1572, 416.972. “Substantial work activity” is work activity that involves doing significant physical or mental activities. 20 C.F.R. §§ 404.1572(a), 416.972(a). “Gainful work activity” is work that is usually done for pay

or profit, whether or not a profit is realized. 20 C.F.R. §§ 404.1572(b), 416.972(b).

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
William Ludwig v. Michael Astrue
681 F.3d 1047 (Ninth Circuit, 2012)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Lingenfelter v. Astrue
504 F.3d 1028 (Ninth Circuit, 2007)
Vernoff Ex Rel. Vernoff v. Astrue
568 F.3d 1102 (Ninth Circuit, 2009)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Jasim Ghanim v. Carolyn W. Colvin
763 F.3d 1154 (Ninth Circuit, 2014)
Igor Zavalin v. Carolyn W. Colvin
778 F.3d 842 (Ninth Circuit, 2015)

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Arnell v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arnell-v-saul-idd-2022.