Cramer v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJanuary 26, 2024
Docket2:22-cv-01644
StatusUnknown

This text of Cramer v. Commissioner of Social Security (Cramer 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
Cramer v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

1 2 3 4

5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 MICHAEL C., 8 Plaintiff, CASE NO. C22-1644-BAT 9 v. ORDER AFFIRMING THE COMMISSIONER AND DISMISSING 10 COMMISSIONER OF SOCIAL SECURITY, THE CASE WITH PREJUDICE 11 Defendant. 12 13 Plaintiff Michael C. seeks review of the partially favorable decision finding him disabled 14 beginning on March 30, 2015, but not disabled before that date; denying his application for 15 Disability Insurance Benefits; and granting his application for Supplemental Security Income 16 beginning on the established onset date. Plaintiff contends the ALJ failed to fully develop the 17 record and thereby violated his constitutional right to due process; he further argues the ALJ 18 misevaluated the medical evidence and plaintiff’s testimony and the resulting residual functional 19 capacity determination and non-disability finding are erroneous. Dkt. 33. He seeks remand for an 20 immediate award of benefits. Id. The Court AFFIRMS the Commissioner’s final decision and 21 DISMISSES the case with prejudice. 22 // 23 // 1 BACKGROUND 2 Plaintiff was 52 years old on his alleged onset date and 56 years old on his established 3 onset date. Tr. 19. He has at least a high school education and has worked as a building 4 maintenance repairperson, automotive accessories salesperson, title searcher, merchandise

5 displayer, cemetery worker, and home restoration cleaner. Tr. 19, 58. For purposes of Disability 6 Insurance Benefits, plaintiff’s date last insured was December 31, 2013. Tr. 9. 7 Plaintiff previously filed an application for benefits that was denied and became 8 administratively final on June 27, 2013. Tr. 5. He filed the current application for benefits on 9 March 30, 2015, alleging disability as of May 1, 2011; he later amended his alleged onset date to 10 June 28, 2013. Tr. 35, 621. In October 2017, the ALJ issued a decision finding plaintiff not 11 disabled. Tr. 256-68. Plaintiff appealed, and while the case was pending before the Ninth Circuit 12 Court of Appeals, the parties stipulated the case be remanded for a new hearing before a different 13 ALJ. Tr. 315. On remand, after conducting a new hearing, the ALJ issued a decision finding 14 plaintiff disabled as of March 30, 2015, but not disabled before that date. Tr. 5-22. Plaintiff now

15 seeks review of that decision. 16 THE ALJ’S DECISION 17 Utilizing the five-step disability evaluation process,1 the ALJ found that plaintiff had not 18 engaged in substantial gainful activity since the alleged onset date; that plaintiff had the 19 following severe impairments: fatty liver disease and cardiac disease; and that these impairments 20 did not meet or equal the requirements of a listed impairment. Tr. 9-11. The ALJ found that 21 between his alleged onset date and his date last insured, plaintiff had the residual functional 22 capacity to perform light work except he could occasionally climb ladders, ropes, and 23

1 20 C.F.R. §§ 404.1520, 416.920. 1 scaffolding, he must avoid concentrated exposure to hazards and respiratory irritants, and he 2 would be off task for 10% of the workday; the ALJ also found that plaintiff had the same 3 residual functional capacity for the period beginning on March 30, 2015. Tr. 11. The ALJ found 4 that on December 31, 2013, plaintiff was capable of performing his past relevant work as an auto

5 parts salesperson and title searcher. Tr. 18. The ALJ found beginning on March 30, 2015, 6 plaintiff’s RFC prevented him from performing any past relevant work and there were no jobs 7 that exist in substantial numbers in the national economy that plaintiff could perform. Tr. 20-21. 8 The ALJ therefore found plaintiff was not disabled prior to March 30, 2015, but that he became 9 disabled on that date. Tr. 21. 10 DISCUSSION 11 The Court will reverse the ALJ’s decision only if it was not supported by substantial 12 evidence in the record as a whole or if the ALJ applied the wrong legal standard. Molina v. 13 Astrue, 674 F.3d 1104, 1110 (9th Cir. 2012). The ALJ’s decision may not be reversed on account 14 of an error that is harmless. Id. at 1111. The Court may neither reweigh the evidence nor

15 substitute its judgment for that of the Commissioner. Thomas v. Barnhart, 278 F.3d 947, 954 16 (9th Cir. 2002). Where the evidence is susceptible to more than one rational interpretation, the 17 Court must uphold the Commissioner’s interpretation. Id. 18 A. Due process 19 Plaintiff argues the ALJ failed to develop the record fully and fairly and thereby violated 20 plaintiff’s constitutional right to procedural due process. Dkt. 33 at 3. 21 At the hearing, the ALJ began by discussing the exhibits as follows: “I have in 22 [plaintiff’s] electronic file documents that have been labeled B-1A through B-11F, and there 23 have been attachments of the prior claim that have been marked 1A through 21F. Counsel, any 1 objection to these documents being admitted into evidence as exhibits?” Tr. 35. Plaintiff’s 2 counsel, who represents plaintiff before this Court, responded he had no objection. Id. Despite 3 admitting the evidence from the prior claim into the record, the list of exhibits attached to the 4 ALJ’s decision did not include that evidence. Tr. 25-30. The administrative record initially

5 submitted to this Court in conjunction with this appeal also did not include the evidence from the 6 prior claim. Dkt. 15. The Commissioner later submitted a corrected administrative record that 7 constituted the full and complete administrative record, and the Court issued a new scheduling 8 order based on the submission of the corrected administrative record. Dkt. 26, 29. Plaintiff 9 sought, and the Court granted, an extension of 13 days to submit an opening brief in this case. 10 Dkt. 30, 32. 11 Plaintiff argues the omission of a complete exhibit list from the ALJ’s decision is a 12 constitutional due process violation. Dkt. 33 at 3. He asserts although the Commissioner 13 attempted to cure this error by filing an amended administrative record that includes the missing 14 exhibit, the ALJ’s failure to identify the evidence she considered violated a basic procedural

15 requirement and this Court should reverse the unfavorable portion of the decision. Id. 16 The Commissioner responds plaintiff has not shown any harm from the ALJ’s failure to 17 include the documents in the exhibit list, much less harm that rises to the level of a due process 18 violation. Dkt. 38 at 2-3. The Commissioner notes the ALJ identified all the exhibits at the 19 hearing, plaintiff’s counsel affirmed that those exhibits constituted the complete record, and the 20 ALJ discussed documents from both groups of records (current and prior claims) in the decision. 21 Id. 22 Plaintiff asserts in reply that including an accurate exhibit list in a decision is a basic 23 procedural requirement and that in reviewing the ALJ’s decision, plaintiff had no way of 1 knowing precisely which evidence the ALJ was citing in support of her findings, since the 2 evidence was not all identified in the decision. Dkt. 39 at 2. He asserts the Court reviews the 3 ALJ’s decision as written, and the decision as written does not identify the evidence on which 4 the ALJ based her decision. Id.

5 Plaintiff’s bare assertions of a due process violation do not establish there was such a 6 violation, or he was harmed by any such violation.

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

Related

Perez v. Barnhart
415 F.3d 457 (Fifth Circuit, 2005)
Chuang Investments v. Marriott Family
81 F.3d 13 (First Circuit, 1996)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
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)
Meanel v. Apfel
172 F.3d 1111 (Ninth Circuit, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Cramer v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cramer-v-commissioner-of-social-security-wawd-2024.