Duthorn v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedMarch 4, 2024
Docket3:23-cv-08045
StatusUnknown

This text of Duthorn v. Commissioner of Social Security Administration (Duthorn v. Commissioner of Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Duthorn v. Commissioner of Social Security Administration, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Samuel John Duthorn, No. CV-23-08045-PCT-SMB

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 At issue is the denial of Samuel John Duthorn’s Application for Social Security 16 Disability Insurance (“SSDI”) benefits by the Social Security Administration (“SSA”) 17 under the Social Security Act (the “Act”). Plaintiff filed a Complaint, (Doc. 1), and an 18 Opening Brief, (Doc. 10), seeking judicial review of that denial. Defendant SSA filed an 19 Answering Brief, (Doc. 14), to which Plaintiff replied, (Doc. 15). After reviewing the 20 parties’ briefs, the Administrative Record, (Doc. 7), and the Administrative Law Judge’s 21 (“ALJ”) decision, (Doc. 7-3 at 17–29), the Court will affirm the ALJ’s decision for the 22 reasons addressed herein. 23 I. BACKGROUND 24 Plaintiff protectively filed an Application for SSDI benefits in on August 5, 2020, 25 alleging disability beginning January 1, 2020. (Id. at 17.) Plaintiff’s claim was initially 26 denied on December 8, 2020. (Id.) After reconsideration, Plaintiff’s claim was again 27 denied on March 11, 2021. (Id.) A hearing was held before ALJ Carla Waters on 28 September 22, 2021. (Id.) After considering the medical evidence and opinions, the ALJ 1 determined that Plaintiff suffered from severe impairments lumbar and cervical 2 degenerative disc disease, status post discectomy laminectomy, post laminectomy 3 syndrome, a history of cauda equina syndrome, osteoarthritis, brachial neuritis, chronic 4 pain syndrome, obesity, hypertension and an anxiety disorder. (Id. at 20.) However, the 5 ALJ concluded that despite these impairments Plaintiff had the residual functional capacity 6 (“RFC”) to perform light work as defined in 20 CFR § 416.967(b) with some additional 7 limitations. (Id. at 22.) In light of this, the ALJ concluded that Plaintiff is not disabled. 8 (Id. at 29.) Thereafter, the Appeals Council denied Plaintiff’s Request for Review of the 9 ALJ’s decision—making it the SSA Commissioner’s (the “Commissioner”) final 10 decision—and this appeal followed. (Id. at 2–5.) 11 II. LEGAL STANDARD 12 An ALJ’s factual findings “shall be conclusive if supported by substantial 13 evidence.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). The Court may set aside 14 the Commissioner’s disability determination only where it is not supported by substantial 15 evidence or is based on legal error. Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007). 16 Substantial evidence is relevant evidence that a reasonable person might accept as adequate 17 to support a conclusion when considering the record as a whole. Id. Generally, “[w]here 18 the evidence is susceptible to more than one rational interpretation, one of which supports 19 the ALJ’s decision, the ALJ’s conclusion must be upheld.” Thomas v. Barnhart, 278 F.3d 20 47, 954 (9th Cir. 2002). In determining whether to reverse an ALJ’s decision, district 21 courts review only those issues raised by the party challenging the decision. See Lewis v. 22 Apfel, 236 F.3d 503, 517 n.13 (9th Cir. 2001). 23 III. DISCUSSION 24 Plaintiff argues that the ALJ committed harmful error by (1) incorrectly assuming 25 that she was bound to adopt the physical restrictions from a previous decision’s RFC 26 pursuant to Chavez v. Bowen, 844 F.2d 691 (9th Cir. 1998) and (2) not properly considering 27 Plaintiff’s mental impairment in the RFC. (Doc. 10.) The Commissioner counters that the 28 ALJ properly interpreted Chavez and properly considered Plaintiff’s mental impairment. 1 (Doc. 14.) After reviewing the administrative record, the Court agrees with the 2 Commissioner for the following reasons. 3 A. Reliance on Prior Decision 4 “The principles of res judicata apply to administrative decisions, although the 5 doctrine is applied less rigidly to administrative proceedings than to judicial proceedings.” 6 Chavez, 844 F.2d at 693. “The claimant, in order to overcome the presumption of 7 continuing non-disability arising from the first administrative law judge’s findings of non- 8 disability, must prove changed circumstances indicating a greater disability.” Id. (cleaned 9 up). Changed circumstances may include “[a]n increase in the severity of the claimant's 10 impairment” or “the existence of an impairment not considered in the previous 11 application.” Lester v. Chater, 81 F.3d 821, 827 (9th Cir. 1995). 12 Even if a claimant rebuts the presumption, some of the previous ALJ’s findings may 13 be entitled to preclusive effect. Chavez, 844 F.2d at 694. The previous ALJ’s findings 14 regarding a claimant’s RFC, education, and work experience should not be disturbed unless 15 the claimant presents new and material evidence that implicates those findings. Id. 16 Following the Ninth Circuit’s ruling in Chavez, the SSA adopted Acquiescence Ruling 97- 17 4(9). SSAR 97-4(9), 1997 WL 742758. This ruling requires adjudicators to adopt the 18 findings from the final decision on a prior claim unless there is new and material evidence 19 related to the finding. See id. 20 Here, Plaintiff argues that the ALJ “incorrectly assumed that she was bound by the 21 physical restrictions assessed by the ALJ in the prior decision.” (Doc. 10 at 10.) Plaintiff 22 contends that the ALJ’s finding of new material evidence allowed her to find greater 23 exertional restrictions than the prior decision’s RFC finding. (Id. at 11.) Overall, Plaintiff 24 argues that the error is not harmless because if Plaintiff were limited to sedentary exertion, 25 it would invoke a finding of disability. (Id.) The Commissioner argues that despite this 26 assumption, the ALJ did not adopt the previous findings and therefore did not err. (Doc. 27 14 at 6–7.) 28 In a previous ALJ decision from June 2017, Plaintiff was found not disabled. (Doc. 1 7-4.) Here, the ALJ noted that decision, but held that the Plaintiff rebutted the presumption 2 of continuing non-disability due to the presentation of new material evidence that was not 3 previously considered and the Plaintiff’s change in age category. (Doc. 7-3 at 27.) The 4 ALJ then stated “[T]he evidence is material, as that term is defined for purposes of Chavez 5 and AR 97-4(9), regarding the findings of the Prior Decision. The undersigned is required 6 by Chavez and AR 97-4(9) to adopt those findings in this decision.” (Id.) 7 The Commissioner states that inclusion of this language “appears to be a scrivener’s 8 error.” (Doc. 14 at 6.) The Court agrees. Despite including this language, the ALJ did not 9 adopt the previous ALJ’s physical RFC findings. Instead, the ALJ added further physical 10 limitations regarding standing and walking times and occasional climbing of ramps and 11 crawling. (Compare Doc. 7-3 at 22, with Doc. 7-4 at 10.) Although the ALJ stated that 12 the Chavez presumption applied, the ALJ did not functionally apply the presumption. Her 13 analysis did not proceed as if she were bound by the prior findings. Rather, she proceeded 14 to evaluate Plaintiff’s claim on the merits and thoroughly analyzed the record. (See Doc. 15 7-3.) As a result of her analysis, she modified Plaintiff’s RFC. (Id. at 22.) If she believed 16 she were bound by the previous findings, she would not have done this. In short, the ALJ’s 17 inclusion of this language was, at most, harmless error. Stout v. Comm’r, Soc. Sec.

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Related

Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Jasim Ghanim v. Carolyn W. Colvin
763 F.3d 1154 (Ninth Circuit, 2014)
Gavin Buck v. Nancy Berryhill
869 F.3d 1040 (Ninth Circuit, 2017)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Lester v. Chater
81 F.3d 821 (Ninth Circuit, 1995)
Solomon v. Comm'r of Soc. Sec. Admin.
376 F. Supp. 3d 1012 (D. Arizona, 2019)

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Duthorn v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/duthorn-v-commissioner-of-social-security-administration-azd-2024.