Dickens v. Kijakazi

CourtDistrict Court, E.D. Washington
DecidedSeptember 17, 2021
Docket1:20-cv-03145
StatusUnknown

This text of Dickens v. Kijakazi (Dickens v. Kijakazi) 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
Dickens v. Kijakazi, (E.D. Wash. 2021).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Sep 17, 2021

3 UNITED STATES DISTRICT COURT SEAN F. MCAVOY, CLERK EASTERN DISTRICT OF WASHINGTON 4 MICHELE D., No. 1:20-cv-03145-SMJ 5 Plaintiff, 6 ORDER REMANDING CASE v. 7 KILOLO KIJAKAZI, Acting 8 Commissioner of Social Security Administration, 9 Defendant. 10

11 Before the Court, without oral argument, are Plaintiff’s Motion for Summary 12 Judgment, ECF No. 23, and Defendant’s Motion to Remand, ECF No. 25. The 13 parties agree that the ALJ erred by improperly evaluating the medical opinion 14 evidence, improperly rejecting Plaintiff’s opinion evidence, and improperly 15 rejecting lay witness testimony. See ECF No. 23 at 2; ECF No. 25 at 3. But they 16 disagree about the appropriate remedy. Compare ECF No. 26 with ECF No. 28. 17 Plaintiff asks this Court to either remand for an award of benefits or with 18 instructions for a de novo hearing, ECF No. 26 at 2, while Defendant asks the Court 19 to remand without the mandatory instruction of either a de novo hearing or award 20 of benefits, ECF No. 28 at 4. Having reviewed the motions and the file in this matter, 1 the Court is fully informed and remands this matter under Defendant’s requested 2 conditions. The Court thus reverses and remands the matter for further

3 administrative proceedings before an Administrative Law Judge (ALJ) and a new 4 decision regarding Plaintiff’s applications for benefits under the Social Security 5 Act.

6 PROCEDURAL HISTORY1 7 Plaintiff filed for disability in 2013. AR 171. In 2015, an ALJ issued an 8 unfavorable decision. AR 16. Plaintiff appealed, and this Court remanded for 9 additional proceedings. AR 472. In 2020, the ALJ once again denied her claim, and

10 Plaintiff again appealed. AR 386–99; ECF No. 1. 11 LEGAL STANDARD 12 A. Remand for Benefits

13 “The decision whether to remand a case for additional evidence, or simply to 14 award benefits is within the discretion of the court.” Sprague v. Bowen, 812 F.2d 15 1226, 1232 (9th Cir. 1987). It is proper to remand for an immediate award of 16 benefits only when: “(1) the record has been fully developed and further

17 administrative proceedings would serve no useful purpose; (2) the ALJ has failed 18

19 1 The facts of the case are set forth in the administrative record and the parties’ briefs. See, e.g., ECF No. 23 at 4–8. The parties have discussed any additional 20 relevant facts in their briefing. See generally ECF Nos. 23, 25, 27 & 28. The Court thus provides only a short procedural summary here. 1 to provide legally sufficient reasons for rejecting evidence, whether claimant 2 testimony or medical opinion; and (3) if the improperly discredited evidence were

3 credited as true, the ALJ would be required to find the claimant disabled on 4 remand.” Garrison v. Colvin, 759 F.3d 995, 1020 (9th Cir. 2014). The Ninth Circuit 5 has “stated or implied that it would be an abuse of discretion for a district court not

6 to remand for an award of benefits” when these three conditions are met. Id. But 7 “[i]n rare instances, though each of the credit-as-true factors is met, the record as a 8 whole leaves serious doubt as to whether the claimant is actually disabled.” Trevizo 9 v. Berryhill, 871 F.3d 664, 683 n.11 (9th Cir. 2017).

10 In other words, a remand for award of benefits is appropriate only if the 11 record, taken as a whole, leaves “not the slightest uncertainty as to the outcome.” 12 Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1101 (9th Cir. 2014).

13 B. De Novo Hearing 14 The Social Security Act (“the Act”) requires that the “Commissioner shall 15 give such applicant and such other individual reasonable notice and opportunity for 16 a hearing.” 42 U.S.C. § 405(b)(1). However, the Act does not require that a claimant

17 receive a new hearing on remand. See 42 U.S.C. § 405(g) (“The court shall have 18 power to enter . . . a judgment . . . with or without remanding the cause for a 19 rehearing.”). Nor do the regulations require that an ALJ hold a new hearing in every

20 remand: 1 The Appeals Council may remand a case to an administrative law judge so that he or she may hold a hearing and issue a decision or a 2 recommended decision. The Appeals Council may also remand a case in which addiction evidence is needed or additional action by the 3 administrative law judge is required.

4 20 C.F.R. § 404.977(a) (emphasis added); see also 20 C.F.R. § 404.983(e) (the 5 procedures outlined in Section 404.977 apply to cases remanded by federal courts). 6 Where a de novo hearing would not provide helpful insight on remand, one is not 7 required. 8 DISABILITY DETERMINATION 9 A “disability” is defined, for the purposes of receiving social security 10 benefits, as the “inability to engage in any substantial gainful activity by reason of 11 any medically determinable physical or mental impairment which can be expected 12 to result in death or which has lasted or can be expected to last for a continuous

13 period of not less than twelve months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). 14 The ALJ uses a five-step sequential evaluation process to determine whether a 15 claimant qualifies for disability benefits. 20 C.F.R. §§ 404.1520, 416.920. 16 At step one, the ALJ considers the claimant’s work activity, if any. 20 C.F.R.

17 §§ 404.1520(a)(4)(i),(b), 416.920(a)(4)(i),(b). If the claimant is doing any 18 substantial gainful activity, the ALJ will find the claimant not disabled and deny 19 their claim. Id. If the claimant is not doing any substantial gainful activity, the

20 evaluation proceeds to step two. 1 At step two, the ALJ considers the medical severity of the claimant’s 2 impairment(s). 20 C.F.R. §§ 404.1520(a)(4)(ii), (c), 416.920(a)(4)(ii), (c). If they

3 do not have a severe medically determinable physical or mental impairment that 4 meets the twelve-month duration requirement in Section 404.1509, or a 5 combination of impairments that is severe and meets the duration requirement, the

6 ALJ will find the claimant not disabled and deny their claim. Id. If the claimant 7 does have a severe physical or mental impairment, the evaluation proceeds to step 8 three. 9 At step three, the ALJ also considers the medical severity of the claimant’s

10 impairment(s). 20 C.F.R. §§ 404.1520(a)(4)(iii), (d), 416.920(a)(4)(iii), (d). If they 11 have an impairment(s) that meets or equals one of the Social Security 12 Administration’s listings in appendix 1 of this subpart and meets the duration

13 requirement, the ALJ will find the claimant disabled. Id.; 404 Subpt. P App. 1. If 14 their impairment(s) does not meet or equal a listed impairment, the evaluation 15 proceeds to step four. 16 At step four, the ALJ considers the claimant’s residual functional capacity

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Dickens v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dickens-v-kijakazi-waed-2021.