Daly v. O'Malley

CourtDistrict Court, E.D. Washington
DecidedMay 20, 2024
Docket4:23-cv-05174
StatusUnknown

This text of Daly v. O'Malley (Daly v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daly v. O'Malley, (E.D. Wash. 2024).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 May 20, 2024 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 KIP D., NO. 4:23-CV-5174-TOR 8 Plaintiff, ORDER DENYING PLAINTIFF’S 9 v. MOTION FOR SUMMARY JUDGMENT 10 MARTIN O’MALLEY, Commissioner of Social Security, 11 Defendant. 12

13 BEFORE THE COURT is Plaintiff’s Motion for Summary Judgment. ECF 14 No. 7. The matter was submitted for consideration without oral argument. The 15 Court has reviewed the administrative record and the parties’ completed briefing 16 and is fully informed. For the reasons discussed below, Plaintiff’s Motion for 17 Summary Judgment (ECF No. 7) is DENIED and the final order of the Social 18 Security Commissioner is AFFIRMED. 19 JURISDICTION 20 The Court has jurisdiction over this action pursuant to 42 U.S.C. § 405(g). 1 STANDARD OF REVIEW 2 A district court’s review of a final decision of the Commissioner of Social

3 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 4 limited: the Commissioner’s decision will be disturbed “only if it is not supported 5 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153,

6 1158 (9th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence” means 7 relevant evidence that “a reasonable mind might accept as adequate to support a 8 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, 9 substantial evidence equates to “more than a mere scintilla[,] but less than a

10 preponderance.” Id. In determining whether this standard has been satisfied, a 11 reviewing court must consider the entire record as a whole rather than searching 12 for supporting evidence in isolation. Id.

13 In reviewing a denial of benefits, a district court may not substitute its 14 judgment for that of the Commissioner. If the evidence in the record “is 15 susceptible to more than one rational interpretation, [the court] must uphold the 16 [administrative law judge’s] (ALJ’s) findings if they are supported by inferences

17 reasonably drawn from the record.” Molina v. Astrue, 674 F.3d 1104, 1111 (9th 18 Cir. 2012) (citation omitted). Further, a district court “may not reverse an ALJ’s 19 decision on account of an error that is harmless.” Id. An error is harmless “where

20 it is inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1 1115 (quotation and citation omitted). The party appealing the ALJ’s decision 2 bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S.

3 396, 409–10 (2009). 4 FIVE-STEP SEQUENTIAL EVALUATION PROCESS 5 A claimant must satisfy two conditions to be considered “disabled” within

6 the meaning of the Social Security Act. First, the claimant must be “unable to 7 engage in any substantial gainful activity by reason of any medically determinable 8 physical or mental impairment which can be expected to result in death or which 9 has lasted or can be expected to last for a continuous period of not less than twelve

10 months.” 42 U.S.C. § 423(d)(1)(A). Second, the claimant’s impairment must be 11 “of such severity that he is not only unable to do his previous work[,] but cannot, 12 considering his age, education, and work experience, engage in any other kind of

13 substantial gainful work which exists in the national economy.” 42 U.S.C. 14 § 423(d)(2)(A). 15 The Commissioner has established a five-step sequential analysis to 16 determine whether a claimant satisfies the above criteria. See 20 C.F.R. §

17 404.1520(a)(4)(i)–(v). At step one, the Commissioner considers the claimant’s 18 work activity. 20 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in 19 “substantial gainful activity,” the Commissioner must find that the claimant is not

20 disabled. 20 C.F.R. § 404.1520(b). 1 If the claimant is not engaged in substantial gainful activities, the analysis 2 proceeds to step two. At this step, the Commissioner considers the severity of the

3 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers 4 from “any impairment or combination of impairments which significantly limits 5 [his] physical or mental ability to do basic work activities,” the analysis proceeds

6 to step three. 20 C.F.R. § 404.1520(c). If the claimant’s impairment does not 7 satisfy this severity threshold, however, the Commissioner must find that the 8 claimant is not disabled. Id. 9 At step three, the Commissioner compares the claimant’s impairment to

10 several listed impairments recognized by the Commissioner to be so severe as to 11 preclude a person from engaging in substantial gainful activity. 20 C.F.R. § 12 404.1520(a)(4)(iii). If an impairment is as severe or more severe than one of the

13 enumerated impairments, the Commissioner must find the claimant disabled and 14 award benefits. 20 C.F.R. § 404.1520(d). 15 If the severity of the claimant’s impairment meets or exceeds the severity of 16 the enumerated impairments, the Commissioner must pause to assess the

17 claimant’s “residual functional capacity.” Residual functional capacity (RFC) is 18 defined generally as the claimant’s ability to perform physical and mental work 19 activities on a sustained basis despite his limitations and is relevant to both the

20 fourth and fifth steps of the analysis. 20 C.F.R. § 404.1545(a)(1). 1 At step four, the Commissioner considers whether, in view of the claimant’s 2 RFC, the claimant is capable of performing work that he has previously performed

3 (“past relevant work”). 20 C.F.R. § 404.1520(a)(4)(iv). If the claimant is capable 4 of performing past relevant work, the Commissioner must find that the claimant is 5 not disabled. 20 C.F.R. § 404.1520(f). If the claimant is incapable of performing

6 such work, the analysis proceeds to step five. 7 At step five, the Commissioner considers whether, in view of the claimant’s 8 RFC, the claimant is capable of performing other work in the national economy. 9 20 C.F.R. § 404.1520(a)(4)(v). In making this determination, the Commissioner

10 must also consider vocational factors such as the claimant’s age, education and 11 work experience. Id.

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Daly v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daly-v-omalley-waed-2024.