Beatty v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedApril 4, 2022
Docket3:21-cv-05694
StatusUnknown

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

Bluebook
Beatty v. Commissioner of Social Security, (W.D. Wash. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 Marcia B., Case No. 21-cv-05694-TLF 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL SECURITY, DECISION TO DENY BENEFITS 9 Defendant. 10

11 Plaintiff has brought this matter for judicial review of defendant’s denial of her 12 application for supplemental security income (SSI) benefits. 13 The parties have consented to have this matter heard by the undersigned 14 Magistrate Judge. 28 U.S.C. § 636(c); Federal Rule of Civil Procedure 73; Local Rule 15 MJR 13. 16 I. ISSUES FOR REVIEW 17 A. Whether the ALJ Properly Considered Using the Older Age Category 18 B. Whether the ALJ Failed to Properly Evaluate Medical Opinion Evidence 19

20 II. BACKGROUND 21 Plaintiff first received SSI benefits in May 1993. Administrative Record (“AR”) 22 246. Plaintiff continued to receive benefits until her incarceration in 2015. AR 448. 23 Plaintiff was released from prison in July 2017 and protectively filed an application for 24 SSI on May 10, 2018. AR 107-08. Plaintiff’s application was denied upon official review 1 (AR 121) and upon reconsideration (AR 141). After plaintiff filed a request for a hearing, 2 Administrative Law Judge (“ALJ”) Chris Stuber held a hearing on October 23, 2020. AR 3 61–91. On November 30, 2020, ALJ Stuber issued a decision finding that plaintiff has 4 not been disabled since filing her May 2018 application. AR 27–60.

5 Plaintiff seeks judicial review of the ALJ’s November 30, 2020 decision. Dkt. 10. 6 III. STANDARD OF REVIEW 7 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s 8 denial of Social Security benefits if the ALJ’s findings are based on legal error or not 9 supported by substantial evidence in the record as a whole. Revels v. Berryhill, 874 10 F.3d 648, 654 (9th Cir. 2017). Substantial evidence is “such relevant evidence as a 11 reasonable mind might accept as adequate to support a conclusion.” Biestek v. 12 Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations omitted). 13 IV. DISCUSSION 14 In this case, the ALJ found that plaintiff had the following severe impairments:

15 fibromyalgia; neuropathy; degenerative disc disease of the lumbar spine; cirrhosis; 16 degenerative joint disease of the left shoulder; obesity; post-traumatic stress disorder 17 (PTSD); a major depressive disorder; and a borderline personality disorder. AR 37-38. 18 Based on the limitations stemming from these impairments, the ALJ found that plaintiff 19 could perform a reduced range of light work. AR 41-42. 20 Relying on vocational expert (“VE”) testimony, the ALJ found at step four that 21 plaintiff could not perform her past relevant work, but could perform other light, unskilled 22 jobs at step five of the sequential evaluation; therefore, the ALJ determined at step five 23 that plaintiff was not disabled since filing her application in May 2018. AR 53.

24 1 A. Whether the ALJ Properly Considered Using the Older Age Category 2 The claimant’s age category is a vocational factor the Commissioner must 3 consider in deciding whether claimant is disabled. 20 C.F.R. § 404.1563(a). A claimant 4 can belong to three different age categories: “younger person” (under age 50); “closely

5 approaching advanced age” (age 50-54); and “advanced age” (age 55 or older). 20 6 C.F.R. § 404.1563(b)-(e). The regulations further provide that the Commissioner: 7 will not apply the age categories mechanically in a borderline situation. If you are within a few days to a few months of reaching an older age category, and using 8 the older age category would result in a determination or decision that you are disabled, we will consider whether to use the older age category after evaluating 9 the overall impact of all the factors of your case.

10 C.F.R. § 404.1563(b).

11 But “an ALJ is not required to use an older age category, even if the claimant is 12 within a few days or a few months of reaching an older age category.” Lockwood v. 13 Comm'r SSA, 616 F.3d 1068, 1071 (9th Cir. 2010). The ALJ is required by regulation 14 only to consider whether to use an older age category. Id. at 1070. An ALJ is found to 15 have properly considered using the older age category by satisfying the following the 16 requirements: (1) mentioning the plaintiff’s date of birth and age in the decision, (2) 17 citing the appropriate regulations, such as 20 C.F.R. §§ 404.1563, 416.963, to indicate 18 that the ALJ knew of the prohibition against mechanically applying age categories in a 19 borderline situation, and (3) evaluating the overall impact of all the factors of a plaintiff’s 20 case after relying on VE testimony. See Id. at 1072; Strissel v. Colvin, No. C16-0374- 21 RJB-MAT, 2016 WL 6242849, at *3 (W.D. Wash. Oct. 5, 2016). 22 When the ALJ issued his decision, plaintiff was 54 years old and under the 23 “closely approaching advanced age” category, but also two months away from turning 24 1 55 and qualifying for the “advanced age” category. Plaintiff contends that this was a 2 borderline situation and the ALJ erred by failing to consider whether to use an older age 3 category. Dkt. 10, pp. 3–9. 4 Plaintiff argues the first Lockwood factor is not satisfied, because the ALJ

5 mistakenly used plaintiff’s age as of the date when she filed her application -- rather 6 than plaintiff’s age on the date when the ALJ issued the written decision. Dkt. 10, p. 6. 7 In the November 2020 decision, the ALJ wrote: “The claimant was born on 8 January 7, 1966 and was 52 years old, which is defined as an individual closely 9 approaching advanced age, on the date the application was filed (20 CFR 416.963).” 10 AR 52. 11 Plaintiff correctly points out that in November 2020, plaintiff was 54 years old, 12 contrary to what the ALJ wrote. The Commissioner argues, however, that even though 13 the ALJ erred by mis-stating plaintiff’s age, such an error is harmless according to Dattio 14 v. Berryhill, 773 Fed. Appx. 878 (9th Cir. 2019). In that case, the Ninth Circuit found that

15 the ALJ erred in stating that plaintiff was 51 years old, even though at the time of the 16 decision, plaintiff was actually 54 years old. Id. at 882. However, the Ninth Circuit held 17 that the ALJ’s incorrect statement of plaintiff’s age in the decision was harmless, 18 because plaintiff still would have fallen under the “approaching advanced age” category 19 and the ALJ properly considered using the older category. Id. Here, under the 20 regulations, plaintiff would still be under the “closely approaching advanced age” at 21 either 52 or 54 years old. 22 Plaintiff next argues the second Lockwood factor is not met, because the ALJ did 23 not specifically cite the subsection within the regulations to indicate that he was aware

24 1 that he had the discretion to use the older age category. Dkt. 10, p. pp. 6-7; AR 52. In 2 other words, plaintiff contends that the ALJ should have cited to 20 C.F.R. 416.963(b) 3 instead of generally citing to 20 C.F.R.

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Beatty v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beatty-v-commissioner-of-social-security-wawd-2022.