Cahn v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 23, 2023
Docket2:22-cv-00205
StatusUnknown

This text of Cahn v. Commissioner of Social Security (Cahn 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
Cahn v. Commissioner of Social Security, (W.D. Wash. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 DAVID C., Case No. 2:22-cv-00205 7 Plaintiff, v. ORDER REVERSING AND 8 REMANDING DEFENDANT’S COMMISSIONER OF SOCIAL DECISION TO DENY BENEFITS 9 SECURITY, 10 Defendant. 11 12 Plaintiff has brought this matter for judicial review of defendant’s denial of their 13 application for Title II disability insurance benefits. Plaintiff filed their application on May 14 10, 2019, alleging a disability onset date of February 10, 2018. AR 80-182. After a 15 hearing on January 7, 2021, before Administrative Law Judge (ALJ) Glenn Meyers, AR 16 37-78, the ALJ issued a decision on February 3, 2021 and found that plaintiff would be 17 able to perform his past work, and was not disabled. AR 16-31. The Appeals Council 18 denied review. AR 1-3. 19 The parties have consented to have this matter heard by the undersigned 20 Magistrate Judge. 28 U.S.C. § 636(c); Federal Rule of Civil Procedure 73; Local Rule 21 MJR 13. 22 I. ISSUES FOR REVIEW 23 A. Did the ALJ’s decision lack substantial evidence, or depart from legal 24 requirements, when making the determination of Residual Functional Capacity, 1 the application of Step Four criteria, and review of medical evidence concerning 2 plaintiff’s mental health conditions? 3 II. DISCUSSION 4 A. Legal Framework 5 The Court will uphold an ALJ’s decision unless: (1) the decision is based on legal

6 error, or (2) the decision is not supported by substantial evidence. Revels v. Berryhill, 7 874 F.3d 648, 654 (9th Cir. 2017). Substantial evidence is “‘such relevant evidence as a 8 reasonable mind might accept as adequate to support a conclusion.’” Biestek v. 9 Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 10 U.S. 197, 229 (1938)). This requires “more than a mere scintilla,” of evidence. Id. 11 The Commissioner uses a five-step sequential evaluation process to determine if 12 a claimant is disabled. 20 C.F.R. § 416.920. The ALJ assesses the claimant’s RFC to 13 determine, at step four, whether the plaintiff can perform past relevant work, and if 14 necessary, at step five to determine whether the plaintiff can adjust to other work.

15 Kennedy v. Colvin, 738 F.3d 1172, 1175 (9th Cir. 2013). The claimant has the burden of 16 proof at step four to show they do not have the RFC to perform the requirements of past 17 relevant work. 20 C.F.R. § 404.1520(e), (f) Pinto v. Massanari, 249 F.3d 840, 844 (9th 18 Cir. 2001). 19 The ALJ has the burden of proof at step five to show that a significant number of 20 jobs that the claimant can perform exist in the national economy. Tackett v. Apfel, 180 21 F.3d 1094,1099 (9th Cir. 1999); 20 C.F.R. § 416.920(e). 22 The instant case pertains to step four. At step four, “[p]ast work experience must 23 be considered carefully to assure that the available facts support a conclusion regarding 24 the claimant’s ability or inability to perform the functional activities required in [their past 1 work].” SSR 82-62, Titles II & XVI: A Disability Claimant’s Capacity to Do Past Relevant 2 Work, in General, (Jan. 1, 1982). If the record shows the individual is able to perform 3 their past work, the Commissioner will find they are not disabled. 20 C.F.R. § 4 416.920(e). 5 The determination of whether the plaintiff has an RFC that would support a

6 finding that they are able to do their past relevant work requires the ALJ to fully 7 investigate and conduct “a careful appraisal of (1) the individual’s statements as to 8 which past work requirements can no longer be met and the reasons(s) for his or her 9 inability to meet those requirements; (2) medical evidence establishing how the 10 impairment limits ability to meet the physical and mental requirements of the work; and 11 (3) in some cases, supplementary or corroborative information from other sources such 12 as employers, the Dictionary of Occupational Titles, etc., on the requirements of the 13 work as generally performed in the economy.” SSR 82-62 at *3. The DOT is the 14 presumptive authority regarding the manner in which a particular job is generally

15 performed. Johnson v. Shalala, 60 F.3d 1428, 1435 (9th Cir. 1995). 16 Even though the claimant has the burden of proof to show they can no longer 17 perform the requirements of past relevant work, “the ALJ still has a duty to make the 18 requisite factual findings to support [their] conclusion.” Pinto v. Massanari, 249 F.3d 19 840, 844 (9th Cir. 2001). When a finding is made that an individual is capable of 20 performing relevant past work, the decision must contain findings of fact: 21 “1. A finding of fact as to the individual’s RFC. 2. A finding of fact as to the 22 physical and mental demands of the past job/occupation. 3. A finding of fact that the 23 individual’s RFC would permit a return to his or her past job or occupation.” SSR 82-62 24 1 at *4. And, “[t]he decision as to whether the claimant retains the functional capacity to 2 perform past work which has current relevance has far-reaching implications and must 3 be developed and explained fully in the disability decision. Id., at *3. Since this is an 4 important and, in some instances, a controlling issue, every effort must be made to 5 secure evidence that resolves the issue as clearly and explicitly as circumstances

6 permit.” Id. 7 The Court must consider the administrative record as a whole. Garrison v. 8 Colvin, 759 F.3d 995, 1009 (9th Cir. 2014). It must weigh both the evidence that 9 supports, and evidence that does not support, the ALJ’s conclusion. Id. The Court 10 considers in its review only the reasons the ALJ identified and may not affirm for a 11 different reason. Id. at 1010. Furthermore, “[l]ong-standing principles of administrative 12 law require us to review the ALJ’s decision based on the reasoning and actual findings 13 offered by the ALJ—not post hoc rationalizations that attempt to intuit what the 14 adjudicator may have been thinking.” Bray v. Comm’r of SSA, 554 F.3d 1219, 1225-26

15 (9th Cir. 2009) (citations omitted). 16 If the ALJ’s decision is based on a rational interpretation of conflicting evidence, the 17 Court will uphold the ALJ’s finding. Carmickle v. Comm’r of Soc. Sec. Admin., 533 F.3d 18 1155, 1165 (9th Cir. 2008). It is unnecessary for the ALJ to “discuss all evidence 19 presented”. Vincent on Behalf of Vincent v. Heckler, 739 F.2d 1393, 1394-95 (9th Cir. 20 1984) (citation omitted) (emphasis in original). The ALJ must only explain why 21 “significant probative evidence has been rejected.” Id. 22 The Commissioner “will not defer or give any specific evidentiary weight . . . to any 23 medical opinion(s) . . . including those from [the claimant’s] medical sources.” 20 C.F.R.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Broussard
80 F.3d 1025 (Fifth Circuit, 1996)
United States v. Sotomayor-Vazquez
249 F.3d 1 (First Circuit, 2001)
United States v. Borrero-Acevedo
533 F.3d 11 (First Circuit, 2008)
Vincent v. Heckler
739 F.2d 1393 (Ninth Circuit, 1984)
Denise M. Wassenaar v. Office of Personnel Management
21 F.3d 1090 (Federal Circuit, 1994)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Richard Kennedy v. Carolyn W. Colvin
738 F.3d 1172 (Ninth Circuit, 2013)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Kim Brown-Hunter v. Carolyn W. Colvin
806 F.3d 487 (Ninth Circuit, 2015)
Robbins v. Social Security Administration
466 F.3d 880 (Ninth Circuit, 2006)
Kanika Revels v. Nancy Berryhill
874 F.3d 648 (Ninth Circuit, 2017)
Leopoldo Leon v. Nancy Berryhill
880 F.3d 1041 (Ninth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Cahn v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cahn-v-commissioner-of-social-security-wawd-2023.