Bafus v. Kijakazi

CourtDistrict Court, D. Idaho
DecidedJuly 27, 2021
Docket3:19-cv-00152
StatusUnknown

This text of Bafus v. Kijakazi (Bafus v. Kijakazi) 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
Bafus v. Kijakazi, (D. Idaho 2021).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

ERIKA B., Case No. 3:19-CV-00152-REP

Plaintiff, MEMORANDUM DECISION AND ORDER vs. (Dkts. 2, 6 & 13) KILOLO KIJAKAZI, Acting Commissioner of Social Security1,

Defendant.

Pending is Petitioner Erika B.’s Petition for Review (Dkt. 2) and an accompanying Brief in Support of Petition to Review (Dkt. 13) appealing the Social Security Administration’s final decision finding her not disabled and denying her claim for disability insurance benefits. See Pet. for Rev. (Dkt. 2). 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. ADMINISTRATIVE PROCEEDINGS Petitioner is a middle-aged woman with a history of obesity, depression, fibromyalgia, and heart problems. On May 3, 2016, after receiving a mitral valve replacement, Petitioner filed an application for social security disability income (“SSDI”) alleging a disability onset date of January 29, 2016. Pt.’s Br. at 2 (Dkt. 13). The claim was denied initially and on reconsideration

1 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo Kijakazi will be substituted, therefore, as the respondent in this suit. Fed. R. Civ. P. 25(d); see also 42 U.S.C. § 405(g). and Petitioner requested a hearing in front of an Administrative Law Judge (“ALJ”). AR2 83. On February 14, 2018, the claim went to a hearing before Administrative Law Judge (“ALJ”) Jesse Shumway. Id. At the hearing, the ALJ received testimony from Petitioner and from a medical expert named Lynne Jahnke, M.D. Id. On March 27, 2018, the ALJ issued a decision that was unfavorable to Petitioner. AR 80-96.

Petitioner appealed this decision to the Appeals Council. As part of this appeal, Petitioner submitted numerous additional medical records to the Appeals Council, including hospital records for treatment that Petitioner received after the ALJ’s decision was issued. AR 2. The Appeals Council declined to exhibit this evidence. Id. The Council subsequently denied Petitioner’s request for review, making the ALJ’s decision the final decision of the Commissioner of Social Security. AR 1-4. Having exhausted her administrative remedies, Petitioner filed this case. Petitioner raises three points of error. First, Petitioner argues that the ALJ did not provide legitimate reasons for giving less than controlling weight to the opinions of Dr. Emily Todd, Petitioner’s treating

physician. Pt.’s Br. at 8-9 (Dkt. 13). Second, Petitioner maintains that the ALJ failed to provide sufficient justification for discrediting Petitioner’s symptom testimony. Id. at 14. Finally, Petitioner contends that the ALJ erred in rejecting the lay witness statements. Id. at 15. 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. 42 U.S.C. § 405(g). In other words, if there is substantial evidence to support the

2 Citations to “AR __” refer to the cited page of the Administrative Record (Dkt. 12). ALJ’s factual decisions, they must be upheld, even when there is conflicting evidence. See Treichler v. Comm’r of Social 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. 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 person of 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 Social 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); Treichler, 775 F.3d at 1098. 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). THE 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

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Related

Richardson v. Perales
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Pierce v. Underwood
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William Ludwig v. Michael Astrue
681 F.3d 1047 (Ninth Circuit, 2012)
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Vernoff Ex Rel. Vernoff v. Astrue
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Igor Zavalin v. Carolyn W. Colvin
778 F.3d 842 (Ninth Circuit, 2015)
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Lester v. Chater
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