Cari v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 27, 2022
Docket3:20-cv-06188
StatusUnknown

This text of Cari v. Commissioner of Social Security (Cari 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
Cari 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 JAYNE C., Case No. 3:20-cv-06188-TLF 7 Plaintiff, v. ORDER AFFIRMING 8 DEFENDANT’S DECISION TO COMMISSIONER OF SOCIAL SECURITY, DENY BENEFITS 9 10 Defendant. 11 12 Plaintiff has brought this matter for judicial review of defendant’s denial of her 13 application for disability insurance benefits. 14 The parties have consented to have this matter heard by the undersigned 15 Magistrate Judge. 28 U.S.C. § 636(c); Federal Rule of Civil Procedure 73; Local Rule 16 MJR 13. 17 I. ISSUES FOR REVIEW 18 A. Did the ALJ commit harmful error in deciding that plaintiff’s 2015 work activity 19 was substantial gainful activity? 20 B. Did the ALJ properly find that plaintiff could perform her past relevant work at 21 step four of the five-step sequential evaluation? 22 C. Did the ALJ properly find that plaintiff could perform other work at step five? 23 D. Does new evidence submitted to the Appeals Council undermine the ALJ’s 24 findings at step four and five? 1 E. Was the ALJ’s decision constitutionally defective? 2 II. BACKGROUND 3 On August 8, 2016, plaintiff filed an application for disability insurance benefits, 4 alleging in that application a disability onset date of April 8, 2012. Administrative Record 5 (“AR”) 509. Plaintiff’s application was denied upon initial review and upon

6 reconsideration. AR 322, 337. A hearing was held before Administrative Law Judge 7 (“ALJ”) Gerald Hill on March 20, 2018. AR 237–89. On July 31, 2018, the ALJ issued a 8 decision finding that plaintiff was not disabled. AR 352–70. On July 24, 2019, the Social 9 Security Appeals Council remanded for a new ALJ hearing and decision on the basis 10 that ALJ Hill did not adequately articulate his reasoning for finding plaintiff could perform 11 her past relevant work. AR 371–75. 12 Following the Appeals Council remand, a new hearing was held before ALJ 13 David Johnson on January 30, 2020. AR 290–321. This led to a new decision on March 14 6, 2020, in which ALJ Johnson found that plaintiff was not disabled. AR 43–68. On

15 October 22, 2020, the Appeals Council denied plaintiff’s request for review. AR 4–10. 16 Plaintiff seeks judicial review of the ALJ’s March 6, 2020 decision. Dkt. 4. 17 III. STANDARD OF REVIEW 18 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s 19 denial of Social Security benefits if the ALJ’s findings are based on legal error or not 20 supported by substantial evidence in the record as a whole. Revels v. Berryhill, 874 21 F.3d 648, 654 (9th Cir. 2017). Substantial evidence is “such relevant evidence as a 22 reasonable mind might accept as adequate to support a conclusion.” Biestek v. 23 Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations omitted). 24 1 IV. DISCUSSION 2 In this case, the ALJ found that plaintiff had the severe, medically determinable 3 impairments of obesity, osteoarthritis, right shoulder abnormalities, status-post right hip 4 replacement, and thyroid abnormalities as of December 31, 2018, her date last insured, 5 in addition to status-post left hip replacement as of October 29, 2018. AR 50.

6 Based on the limitations stemming from these impairments, the ALJ found that 7 plaintiff could perform a reduced range of sedentary work. AR 51. Relying on vocational 8 expert (“VE”) testimony, the ALJ found at step four that plaintiff could perform her past 9 relevant work as a drafter, but also found plaintiff could perform other sedentary, 10 unskilled jobs at step five of the sequential evaluation; therefore, the ALJ determined at 11 both steps four and five that plaintiff was not disabled. AR 59–60. 12 A. Whether the ALJ properly determined that plaintiff performed substantial 13 gainful activity in 2015 14 Plaintiff argues that the ALJ erred in finding that, during a four-month period in

15 2015, her work constituted substantial gainful activity, as opposed to an unsuccessful 16 work attempt. Dkt. 20, pp. 8–9. 17 An unsuccessful work attempt may be found when a claimant works for a period 18 of six months or less and stopped working due to an impairment. 20 C.F.R. § 19 416.974(c). Subsection (2) of this regulation informs claimants that “[t]here must be a 20 significant break in the continuity of your work before we will consider that you began a 21 work attempt that later proved unsuccessful,” and “[y]ou must have stopped working or 22 reduced your work and earnings below the substantial gainful activity earnings level 23 because of your impairment.” 20 C.F.R. § 404.1527(c)(2). 24 1 Here, the ALJ found that “while [plaintiff] did not work from 2012 to 2015, most of 2 that break was for the purpose of education so [plaintiff] could enter a more highly 3 skilled position of the type of work she had been doing, and not because she was 4 medically incapable of working.” AR 49. This finding is not supported by substantial 5 evidence. As the ALJ noted, plaintiff started attending full-time classes in late 2013, over

6 a year after her alleged onset date of April 8, 2012. Id. (citing AR 307). While plaintiff 7 stated that she began taking Computer-Assisted Drafting (“CAD”) classes on a part-time 8 basis in 2010, there is no evidence that she maintained a course schedule from 2012 to 9 2013, or from 2013 to 2015, on a basis that would be comparable to the demands of a 10 full-time job. AR 307. 11 However, while substantial evidence does not support a finding that plaintiff left 12 her job in 2012 to focus on school, the ALJ properly found that plaintiff also did not 13 leave that job due to her disability. 14 The ALJ found plaintiff’s report that she stopped working in 2012 due to fatigue to

15 be inconsistent with the record. AR 49. While the record showed she complained of 16 fatigue in May 2012, she reported her fatigue as “5/10,” which the ALJ reasonably 17 inferred was moderate. Id. (citing AR 826). By July 2012, she reported her energy had 18 improved to “7/10,” which remained consistent through November 2012, her last report. 19 Id. (citing AR 819–24). The ALJ found that plaintiff’s lack of treatment—she did not seek 20 treatment until at least a month after the alleged onset date--and reports of 21 improvement regarding fatigue -- within three months of her alleged onset date -- were 22 inconsistent with her assertion that her work ended because of her impairments. AR 49. 23 Given that plaintiff does not challenge the ALJ’s adverse credibility determination, she 24 1 does not show error with regard to the ALJ’s findings regarding her reasons for leaving 2 work. The ALJ’s decision that plaintiff took time away from work to obtain more training, 3 and then came back to gainful employment in 2015, is supported by substantial 4 evidence. 5 Even if the ALJ erred, plaintiff cannot show this was harmful error. Harmless

6 error principles apply in the Social Security context. Molina v. Astrue, 674 F.3d 1104, 7 1115 (9th Cir. 2012). An error is harmless only if it is not prejudicial to the claimant or 8 “inconsequential” to the ALJ’s “ultimate nondisability determination.” Stout v. Comm’r 9 Soc. Sec. Admin., 454 F.3d 1050, 1055 (9th Cir. 2006); see Molina, 674 F.3d at 1115.

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