Aychillhum v. SSI

CourtDistrict Court, S.D. California
DecidedFebruary 12, 2025
Docket3:24-cv-02018
StatusUnknown

This text of Aychillhum v. SSI (Aychillhum v. SSI) 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
Aychillhum v. SSI, (S.D. Cal. 2025).

Opinion

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10 UNITED STATES DISTRICT COURT 11 SOUTHERN DISTRICT OF CALIFORNIA 12

13 MARSHA M. AYCHILLHUM, Case No. 24-cv-02018-BAS-KSC

14 Plaintiff, ORDER:

15 (1) GRANTING MOTION TO v. PROCEED IN FORMA 16 PAUPERIS (ECF No. 2); AND SSA; SSI, 17 (2) DISMISSING COMPLAINT WITH LEAVE TO AMEND 18 Defendants. 19 20 Plaintiff Marsha M. Aychillhum is self-represented. She filed this lawsuit 21 concerning her Social Security Retirement and Supplemental Security Income. (ECF 22 No. 1.) Plaintiff also filed a Motion to Proceed In Forma Pauperis (“IFP”)—without 23 paying the filing fee. (ECF No. 2.) For the reasons explained below, the Court grants 24 Plaintiff’s Motion to Proceed IFP and dismisses her Complaint with leave to amend. 25 I. Motion for Leave to Proceed IFP 26 Under 28 U.S.C. § 1915, a litigant who because of indigency is unable to pay 27 the required fees or security to commence a legal action may petition the court to 1 the district court’s discretion. Cal. Men’s Colony v. Rowland, 939 F.2d 854, 858 (9th 2 Cir. 1991), rev’d on other grounds, 506 U.S. 194 (1993) (holding that “Section 1915 3 typically requires the reviewing court to exercise its sound discretion in determining 4 whether the affiant has satisfied the statute’s requirement of indigency”). It is well- 5 settled that a party need not be completely destitute to proceed IFP. Adkins v. E.I. 6 DuPont de Nemours & Co., 335 U.S. 331, 339–40 (1948). To satisfy the 7 requirements of 28 U.S.C. § 1915(a), “an affidavit [of poverty] is sufficient which 8 states that one cannot because of his poverty pay or give security for costs . . . and 9 still be able to provide himself and dependents with the necessities of life.” Id. at 10 339. At the same time, however, “the same even-handed care must be employed to 11 assure that federal funds are not squandered to underwrite, at public expense . . . the 12 remonstrances of a suitor who is financially able, in whole or in material part, to pull 13 his own oar.” Temple v. Ellerthorpe, 586 F. Supp. 848, 850 (D.R.I. 1984). 14 District courts, therefore, tend to reject IFP applications where the applicant 15 can pay the filing fee with acceptable sacrifice to other expenses. See, e.g., 16 Stehouwer v. Hennessey, 841 F. Supp. 316, 321 (N.D. Cal. 1994), vacated in part on 17 other grounds, Olivares v. Marshall, 59 F.3d 109 (9th Cir. 1995) (finding that a 18 district court did not abuse its discretion in requiring a partial fee payment from a 19 prisoner who had a $14.61 monthly salary and who received $110 per month from 20 family). Moreover, “in forma pauperis status may be acquired and lost during the 21 course of litigation.” Wilson v. Dir. of Div. of Adult Insts., No. CIV S-06-0791, 2009 22 WL 311150, at *2 (E.D. Cal. Feb. 9, 2009) (citing Stehouwer, 841 F. Supp. at 321); 23 see also Allen v. Kelly, 1995 WL 396860, at *2 (N.D. Cal. June 29, 1995) (holding 24 that a plaintiff who was initially permitted to proceed in forma pauperis should be 25 required to pay his $120 filing fee out of a $900 settlement). Finally, the facts as to 26 the affiant’s poverty must be stated “with some particularity, definiteness, and 27 certainty.” United States v. McQuade, 647 F.2d 938, 940 (9th Cir. 1981). 1 Having reviewed Plaintiff’s IFP application, the Court is persuaded she 2 qualifies for IFP status. Plaintiff has minimal income, including disability payments. 3 (IFP Mot. 2.) She is not employed and lists negligible financial assets. (Id. 2–3.) 4 Her expenses approximate or exceed her minimal income. (Id. 4.) Under these 5 circumstances, the Court finds that requiring Plaintiff to pay the court filing fees 6 would impair her ability to obtain the necessities of life. See Adkins, 335 U.S. at 339. 7 Therefore, the Court grants Plaintiff’s Motion for Leave to Proceed IFP (ECF No. 2). 8 II. Jurisdiction 9 “Federal courts are courts of limited jurisdiction.” Kokkonen v. Guardian Life 10 Ins. Co. of Am., 511 U.S. 375, 377 (1994). “They possess only that power authorized 11 by Constitution and statute, which is not to be expanded by judicial 12 decree.” Id. (internal citations omitted). Hence, “district courts have an 13 ‘independent obligation to address subject-matter jurisdiction sua sponte.’” Grupo 14 Dataflux v. Atlas Glob. Grp., L.P., 541 U.S. 567, 593 (2004) (quoting United States 15 v. S. Cal. Edison Co., 300 F. Supp. 2d 964, 972 (E.D. Cal. 2004)). 16 Plaintiff is seeking benefits governed by Title II and Title XVI of the Social 17 Security Act. Title II “provides old-age, survivor, and disability benefits to insured 18 individuals irrespective of financial need.” Bowen v. Galbreath, 485 U.S. 74, 75 19 (1988). By comparison, Title XVI provides Supplemental Security Income benefits 20 “to financially needy individuals who are aged, blind, or disabled regardless of their 21 insured status.” Id. 22 Judicial review of claims arising under the Social Security Act is authorized 23 by 42 U.S.C. § 405(g). “The Supreme Court has stated that § 405(g) ‘clearly limits 24 judicial review to a particular type of agency action, a ‘final decision of the Secretary 25 made after a hearing.’” Subia v. Comm’r of Soc. Sec., 264 F.3d 899, 902 (9th Cir. 26 2001) (emphasis in original) (quoting Califano v. Sanders, 430 U.S. 99, 108, 97 27 (1977)). A related provision, 42 U.S.C. § 405(h), channels “virtually all legal attacks 1 Term Care, Inc., 529 U.S. 1, 13 (2000); see also Mathews v. Eldridge, 424 U.S. 319, 2 327 (1976) (“The only avenue for judicial review is 42 U.S.C. § 405(g), which 3 requires exhaustion of the administrative remedies provided under the Act as a 4 jurisdictional prerequisite.”). 5 Here, Plaintiff’s Complaint includes few details. She alleges she receives $448 6 in Social Security Retirement and $748 in Supplemental Security Income, and the 7 amounts have “not been increased or decreased.” (Compl. ¶ 4.) Plaintiff alleges she 8 is entitled to more Social Security Retirement and believes the Social Security 9 Administration has “discriminated against [her].” (Id.) She alleges she has asked for 10 “retirement papers” but has not received them.

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Related

Adkins v. E. I. DuPont De Nemours & Co.
335 U.S. 331 (Supreme Court, 1948)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Califano v. Sanders
430 U.S. 99 (Supreme Court, 1977)
Bowen v. Galbreath
485 U.S. 74 (Supreme Court, 1988)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Grupo Dataflux v. Atlas Global Group, L. P.
541 U.S. 567 (Supreme Court, 2004)
Eunice Subia v. Commissioner of Social Security
264 F.3d 899 (Ninth Circuit, 2001)
Stehouwer v. Hennessey
841 F. Supp. 316 (N.D. California, 1994)
Temple v. Ellerthorpe
586 F. Supp. 848 (D. Rhode Island, 1984)
United States v. Southern California Edison Co.
300 F. Supp. 2d 964 (E.D. California, 2004)
Olivares v. Marshall
59 F.3d 109 (Ninth Circuit, 1995)

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