Canfield v. Commissioner of Social Security

CourtDistrict Court, D. Idaho
DecidedSeptember 8, 2025
Docket1:24-cv-00155
StatusUnknown

This text of Canfield v. Commissioner of Social Security (Canfield v. Commissioner of Social Security) 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
Canfield v. Commissioner of Social Security, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

BRIAN J. C., Case No.: 1:24-cv-00155-REP

Plaintiff, MEMORANDUM DECISION AND ORDER vs.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

Pending is Plaintiff Brian J. C.’s Complaint (Dkt. 1), appealing the Social Security Administration’s denial of his disability claim. 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. I. ADMINISTRATIVE PROCEEDINGS On February 17, 2021, Plaintiff protectively filed a Title II application for a period of disability and disability insurance benefits, alleging disability beginning February 5, 2019. This application was originally denied on September 2, 2021, and again on reconsideration on March 3, 2022. On or around April 16, 2022, Plaintiff filed a Request for Hearing before an Administrative Law Judge (“ALJ”). On August 8, 2023, ALJ Laureen Penn held a telephonic hearing, at which time Plaintiff, represented by his attorney Brad Parkinson, testified. The ALJ held a supplemental telephonic hearing on August 16, 2023 to obtain new vocational expert testimony (the Dictionary of Occupational Title (“DOT”) job codes provided at the August 8, 2023 hearing were incorrect). Again, Plaintiff, represented by Mr. Parkinson, testified. Janice L. Bending, an impartial vocational expert, also appeared and testified at the August 16, 2023 hearing.

On August 28, 2023, the ALJ issued a decision denying Plaintiff’s claims. The ALJ found that Plaintiff was not disabled within the meaning of the Social Security Act.1 Plaintiff timely requested review from the Appeals Council. On February 5, 2024, the Appeals Council denied Plaintiff’s Request for Review, making the ALJ’s decision the final decision of the Commissioner of Social Security.

Having exhausted his administrative remedies, Plaintiff brings this case. He raises a single point of error: “the ALJ legally erred by rejecting [his] allegations, relative to his manipulative limitations, without providing adequately-articulated reasons for doing so, as required by SSR 16-3p and the law of this Circuit.” Pl.’s Brief at 1, 9-13 (Dkt. 18). Plaintiff in turn requests that the Court reverse the ALJ’s decision and remand for further

proceedings. Id. at 14. II. 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. See 42 U.S.C. § 405(g). If there is substantial evidence to support the ALJ’s factual decisions, they must be upheld, even when there is

1 Due to the incorrect DOT job codes provided at the August 8, 2023 hearing, the ALJ’s August 28, 2023 decision did not rely on the vocational expert testimony presented at that earlier hearing. AR 15. conflicting evidence. See Treichler v. Comm’r of Soc. 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 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 Soc. Sec., 359 F.3d 1190, 1196 (9th Cir. 2004).

The decision will only be reversed for legal error. Zavalin v. Colvin, 778 F.3d 842, 845 (9th Cir. 2015). 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). III. DISCUSSION

A. 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. §§ 404.1572(a), 416.972(a). “Gainful work

activity” is work that is usually done for pay or profit, whether or not a profit is realized. 20 C.F.R. §§ 404.1572(b), 416.972(b). If the claimant has engaged in SGA, disability benefits are denied regardless of his medical condition, age, education, and work experience. 20 C.F.R. §§ 404.1520(b), 416.920(b). If the claimant has not engaged in SGA, the analysis proceeds to the second step.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
William Ludwig v. Michael Astrue
681 F.3d 1047 (Ninth Circuit, 2012)
Lingenfelter v. Astrue
504 F.3d 1028 (Ninth Circuit, 2007)
Vernoff Ex Rel. Vernoff v. Astrue
568 F.3d 1102 (Ninth Circuit, 2009)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Jasim Ghanim v. Carolyn W. Colvin
763 F.3d 1154 (Ninth Circuit, 2014)
Igor Zavalin v. Carolyn W. Colvin
778 F.3d 842 (Ninth Circuit, 2015)
Kim Brown-Hunter v. Carolyn W. Colvin
806 F.3d 487 (Ninth Circuit, 2015)
Trevizo v. Berryhill
871 F.3d 664 (Ninth Circuit, 2017)

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Canfield v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/canfield-v-commissioner-of-social-security-idd-2025.