Faidley v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedAugust 13, 2024
Docket2:24-cv-00035
StatusUnknown

This text of Faidley v. Commissioner of Social Security (Faidley 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
Faidley 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 SHARMECIA F., 8 Plaintiff, Case No. C24-0035 RSM 9 v. ORDER AFFIRMING AND 10 DISMISSING THE CASE COMMISSIONER OF SOCIAL SECURITY, 11 Defendant. 12

13 Plaintiff seeks review of the denial of her applications for Supplemental Security Income 14 and Disability Insurance Benefits. Plaintiff contends the Administrative Law Judge (ALJ) 15 inappropriately dismissed her request for a hearing. Dkt. 11. As discussed below, the Court 16 AFFIRMS the Commissioner’s final decision and DISMISSES the case with prejudice. 17 BACKGROUND 18 In April 2020, Plaintiff requested a hearing before an ALJ following the agency’s denial 19 of her applications. AR 128–29. On a Notice of Hearing dated December 3, 2020, the agency 20 informed Plaintiff her telephone hearing was scheduled for February 25, 2021. AR 93. The 21 notice stated that if Plaintiff does not attend the hearing, the ALJ “may dismiss” Plaintiff’s 22 request for a hearing unless Plaintiff is able to provide a good reason for not attending. Id. The 23 notice also stated that if Plaintiff would like to change the time and place of the hearing, she 1 must make the request in writing along with an explanation for the request. AR 94. According 2 to the notice, Plaintiff must ask for the change before either 30 days after the receipt of the 3 notice, or five days before the date of Plaintiff’s hearing, whichever is earlier. Id. On a letter 4 dated February 11, 2021, the agency reminded Plaintiff of her telephone hearing. AR 80–83. 5 The record shows the agency contacted Plaintiff on the day of her hearing, but another individual 6 answered the call stating the agency had contacted the wrong number and person. AR 79. On 7 March 3, 2021, the agency sent a letter to Plaintiff stating that because she did not participate in 8 her hearing, she will “need to show good cause if [Plaintiff] still want[s] to have a hearing” with 9 an ALJ. AR 76. The record shows the agency subsequently made several attempts to contact 10 Plaintiff to make sure her address or phone number were updated. See AR 66–75.

11 Plaintiff was eventually notified of a new hearing, in person, scheduled for September 19, 12 2022. AR 48. The Notice of Hearing, dated July 5, 2022, again stated that if Plaintiff does not 13 attend the hearing, the ALJ “may dismiss” Plaintiff’s request, unless Plaintiff is able to provide a 14 good reason for not attending. Id. It again stated that if Plaintiff would like to change the time 15 and place for the hearing, she must make the request in writing either before 30 days after the 16 receipt of the notice, or five days before the date of Plaintiff’s hearing, whichever is earlier. AR 17 49. On a letter dated July 27, 2022, the agency notified Plaintiff that attempts to reach her by 18 phone have been unsuccessful and that she must update her information as soon as possible. AR 19 46. On a letter dated August 22, 2022, the agency reminded Plaintiff of her in-person hearing. 20 AR 43. Similar to the previous communications the agency sent Plaintiff, the letter stated that

21 Plaintiff’s failure to appear in the hearing may be a cause for dismissal. Id. 22 The record shows Plaintiff contacted the agency three days before her scheduled hearing 23 to ask if she could attend the hearing by phone or postpone the hearing entirely. AR 42. The 1 agency employee indicated he would inform the ALJ of her request. Id. An hour before 2 Plaintiff’s hearing, the same employee called Plaintiff to notify her that the ALJ denied her 3 request and that she must attend in person in order to speak to the ALJ. AR 41. Plaintiff did not 4 attend the hearing. AR 35–37. 5 On a letter dated September 22, 2022, the agency informed Plaintiff that because she did 6 not appear at the hearing, she “will need to show good cause if [she] still want[s] to have a 7 hearing with an administrative law judge” by completing, signing, and returning an enclosed 8 form within 10 days. AR 38. On November 21, 2022, the ALJ issued an order of dismissal 9 based on Plaintiff’s failure to appear at the hearing and failure to show good cause for missing 10 the hearing. AR 32–37. On November 9, 2023, the Appeals Council denied Plaintiff’s request

11 for review of the ALJ’s dismissal. AR 4–8. 12 DISCUSSION 13 1. Subject Matter Jurisdiction 14 The Court first discusses whether it has subject matter jurisdiction to consider this matter. 15 This Court has statutory jurisdiction to review “any final decision of the Commissioner of Social 16 Security made after a hearing.” 42 U.S.C. § 405(g). Section 405(g) “contains two separate 17 elements: first, a ‘jurisdictional’ requirement that claims be presented to the agency, and second, 18 a ‘waivable ... requirement that the administrative remedies prescribed by the [Commissioner] be 19 exhausted.’” Smith v. Berryhill, 587 U.S. 478, 479 (citing Mathews v. Eldridge, 424 U.S. 319, 20 328, (1976)). The first element is nonwaivable and is satisfied when a claim for benefits is

21 presented to the Commissioner. Matthews, 424 U.S. at 328. The second is met upon showing 22 that a claimant has exhausted the remedies set forth in the Social Security Act. See 42 U.S.C. § 23 405(g), (h); Yellen v. Saul, 820 F. App’x 615, 616 (9th Cir. 2020); Subia v. Comm. of Soc. Sec., 1 264 F.3d 899 (9th Cir. 2001); Bass v. Soc. Sec. Admin., 872 F.2d 832, 833 (9th Cir. 1989). By 2 properly filing an application for benefits, Plaintiff has satisfied the first element. Matthews, 424 3 U.S. at 329. As for the second element, Section 405(g) of the Act specifically states, “that a civil 4 action may be brought only after (1) the claimant has been party to a hearing held by the 5 [Commissioner], and (2) the [Commissioner] has made a final decision on the claim.” Bass v. 6 Social Sec. Admin., 872 F.2d 832, 833 (9th Cir. 1989). A claimant obtains the Commissioner’s 7 “final decision” about his or her entitlement to benefits only after completing all four steps of the 8 administrative review process: (1) initial determination; (2) reconsideration determination; (3) 9 hearing before an ALJ; and (4) Appeals Council review. See 20 C.F.R. §§ 404.900, 416.1400. 10 The question, therefore, is whether the second element is satisfied given the ALJ’s dismissal of

11 her request for a hearing. 12 An ALJ’s decision to dismiss a request for a hearing is generally not subject to judicial 13 review because when a claimant fails to appear for a scheduled hearing, there is no “final 14 decision” under Section 405(g) by the Commissioner—thus, the claimant fails to exhaust “‘the 15 administrative remedy upon which judicial review depends.’” See Subia, 264 F.3d at 902 16 (quoting Hoye v. Sullivan, 985 F.2d 990, 991 (9th Cir. 1992)). More recently, however, the 17 Supreme Court held that when the Appeals Council dismisses a claimant’s request for review 18 after obtaining a hearing from an ALJ on the merits, the dismissal “qualifies as a ‘final decision 19 … made after a hearing within the meaning of § 405(g).” Smith, 587 U.S. at 489.

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Faidley v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/faidley-v-commissioner-of-social-security-wawd-2024.