Campuzano v. Commissioner of Social Security

CourtDistrict Court, S.D. California
DecidedJuly 22, 2021
Docket3:20-cv-00721
StatusUnknown

This text of Campuzano v. Commissioner of Social Security (Campuzano v. Commissioner of Social Security) 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
Campuzano v. Commissioner of Social Security, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 RUBEN RUIZ CAMPUZANO, Case No.: 20-CV-721-WQH(WVG)

12 Plaintiff, REPORT AND 13 v. RECOMMENDATION ON CROSS- MOTIONS FOR SUMMARY 14 COMMISSIONER OF SOCIAL JUDGMENT SECURITY, 15 Defendant. [Doc. Nos. 12, 15.] 16

17 18 This is an action for judicial review of a decision by the Commissioner of Social 19 Security, denying Plaintiff Ruben Campuzano supplemental security income (“SSI”) 20 benefits under Title XVI of the Social Security Act. The parties have filed cross-motions 21 for summary judgment, and the matter is before the undersigned Magistrate Judge for 22 preparation of a Report and Recommendation. For the reasons stated below, the Court 23 RECCOMNENDS that Defendant’s motion for summary judgment be GRANTED and 24 Plaintiff’s cross-motion for summary judgment be DENIED. 25 / / / 26 / / / 27 / / / 28 / / / 1 I. OVERVIEW OF SOCIAL SECURITY CLAIM PROCEEDINGS 2 Pursuant to the Act, the Social Security Administration (“SSA”) administers the SSI 3 program. 42 U.S.C. § 901. The Social Security Act authorizes the SSA to create a system 4 by which it determines who is entitled to benefits and by which unsuccessful claimants 5 may obtain review of adverse determinations. Id. §§ 423 et seq. Defendant, as Acting 6 Commissioner of the SSA, is responsible for the Act’s administration. Id. § 902(a)(4), 7 (b)(4). 8 A. The SSA’s Sequential Five-Step Process 9 The SSA employs a sequential five-step evaluation to determine whether a claimant 10 is eligible for benefits. 20 C.F.R. §§ 416.920, 404.1520. To qualify for disability benefits 11 under the Act, a claimant must show that (1) he or she suffers from a medically- 12 determinable impairment1 that can be expected to result in death or that has lasted or can 13 be expected to last for a continuous period of twelve months or more and (2) the 14 impairment renders the claimant incapable of performing the work that he or she 15 previously performed or any other substantially gainful employment that exists in the 16 national economy. See 42 U.S.C. §§ 423(d)(1)(A), (2)(A); 1382(c)(3)(A). 17 A claimant must meet both of these requirements to qualify as “disabled” under the 18 Act, id. § 423(d)(1)(A), (2)(A), and bears the burden of proving that he or she “either was 19 permanently disabled or subject to a condition which became so severe as to create a 20 disability prior to the date upon which [his or] her disability insured status expired.” 21 Johnson v. Shalala, 60 F.3d 1428, 1432 (9th Cir. 1995). An administrative law judge 22 (“ALJ”) presides over the five-step process to determine disability. See Barnhart v. 23 Thomas, 540 U.S. 20, 24-25 (2003) (summarizing the five-step process). If the 24 Commissioner finds that a claimant is disabled or not disabled at any step in this process, 25 26 27 1 A medically determinable physical or mental impairment “is an impairment that results from anatomical, physiological, or psychological abnormalities, which can be shown by 28 1 the review process is terminated at that step. Corrao v. Shalala, 20 F.3d 943, 946 (9th Cir. 2 1994). 3 Step one in the sequential evaluation considers a claimant’s “work activity, if any.” 4 20 C.F.R. § 404.1520(a)(4)(i). An ALJ will deny a claimant disability benefits if the 5 claimant is engaged in “substantial gainful activity.” Id. §§ 404.1520(b), 416.920(b). 6 If a claimant cannot provide proof of gainful work activity, the ALJ proceeds to 7 step two to ascertain whether the claimant has a medically severe impairment or 8 combination of impairments. The so-called “severity regulation” dictates the course of this 9 analysis. Id. §§ 404.1520(c), 416.920(c); see also Bowen v. Yuckert, 482 U.S. 137, 140- 10 41 (1987). 11 An ALJ will deny a claimant’s disability claim if the ALJ does not find that a 12 claimant suffers from a severe impairment or combination of impairments which 13 significantly limits the claimant’s physical or mental ability to do “basic work activities.” 14 20 C.F.R. § 404.1520(c). The ability to do “basic work activities” means “the abilities and 15 aptitudes necessary to do most jobs.” Id. §§ 404.1521(b), 416.921(b). 16 However, if the impairment is severe, the evaluation proceeds to step three. At step 17 three, the ALJ determines whether the impairment is equivalent to one of several listed 18 impairments that the SSA acknowledges are so severe as to preclude substantial gainful 19 activity. Id. §§ 404.1520(d), 416.920(d). An ALJ conclusively presumes a claimant is 20 disabled so long as the impairment meets or equals one of the listed impairments. Id. 21 § 404.1520(d). 22 If the ALJ does not deem a claimant disabled—but before formally proceeding to 23 step four—the ALJ must establish the claimant’s Residual Functional Capacity (“RFC”). 24 Id. §§ 404.1520(e), 404.1545(a). An individual’s RFC is his or her ability to do physical 25 and mental work activities on a sustained basis despite limitations from his or her 26 impairments. Id. §§ 404.945(a)(1), 404.1545(a)(1). The RFC analysis considers “whether 27 [the claimant’s] impairment(s), and any related symptoms, such as pain, may cause 28 physical and mental limitations that affect what [the claimant] can do in a work setting.” 1 Id. §§ 404.1545(a)(1), 416.945(a)(1). In establishing a claimant’s RFC, the ALJ must 2 assess relevant medical and other evidence, as well as consider all of the claimant’s 3 impairments, including impairments categorized as non-severe. Id. § 404.1545(a)(3), (e). 4 If an ALJ does not conclusively determine a claimant’s impairment or combination of 5 impairments is disabling at step three, the evaluation advances to step four. 6 At step four, the ALJ uses the claimant’s RFC to determine whether the claimant 7 has the ability to perform the requirements of his or her past relevant work. Id. 8 § 404.1520(f). So long as a claimant has the RFC to carry out his or her past relevant work, 9 the claimant is not disabled. Id. § 404.1560(b)(3). Conversely, if the claimant either cannot 10 perform or does not have any past relevant work, the analysis presses onward. 11 At the fifth and final step of the SSA’s evaluation, the ALJ must verify whether the 12 claimant is able to do any other work in light of his or her RFC, age, education, and work 13 experience. Id. § 404.1520(g). If the claimant is able to do other work, the claimant is not 14 disabled. However, if the claimant is not able to do other work and meets the duration 15 requirement, the claimant is disabled. Id. Although the claimant generally continues to 16 have the burden of proving disability at step five, a limited burden of going forward with 17 the evidence shifts to the SSA. At this stage, the SSA must present evidence demonstrating 18 that other work that the claimant can perform—allowing for his RFC, age, education, and 19 work experience—exists in significant numbers in the national economy. Id. §§ 404.1520, 20 1560(c), 416.920, 404.1512(f). 21 B. SSA Hearings and Appeals Process 22 In accordance with Defendant’s delegation, the Office of Disability Adjudication 23 and Review administers a nationwide hearings and appeals program.

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Bluebook (online)
Campuzano v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/campuzano-v-commissioner-of-social-security-casd-2021.