Garcia v. O'Malley

District Court, E.D. Washington·Decided February 23, 2024·No. 1:23-cv-03112·Unknown

Opinion

1 EASTERUN. SD.I SDTIRSITCRTI COTF CWOAUSRHTI NGTON Feb 23, 2024 2 SEAN F. MCAVOY, CLERK 3 4 EASTERN DISTRICT OF WASHINGTON 6

NO. 1:23-CV-3112-TOR 8 Plaintiff, ORDER AFFIRMING THE SOCIAL 9 v. SECURITY COMMISSIONER’S DENIAL OF BENEFITS Commissioner of Social Security,1 11 Defendant. 12

13 BEFORE THE COURT is Plaintiff’s motion seeking reversal of the Social 14 Security Commissioner’s denial of benefits (ECF No. 9). The Court has reviewed 15

1 Martin O’Malley became the Commissioner of Social Security on December 20, 16 2023. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Martin 17 O’Malley is substituted for Kilolo Kijakazi as the defendant in this suit. No further 18 action need be taken to continue this under the Social Security Act, 42 U.S.C. § 19 405(g). 20 1 the administrative record and the parties’ completed briefing and is fully informed. 2 For the reasons discussed below, the Court DENIES Plaintiff’s motion and

3 AFFIRMS the Social Security Commissioner’s denial of benefits. 5 The Court has jurisdiction under 42 U.S.C. §§ 405(g), 1383(c)(3).

7 A district court’s review of a final decision of the Commissioner of Social 8 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 9 limited: the Commissioner’s decision will be disturbed “only if it is not supported

10 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 11 1158-59 (9th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence” means 12 relevant evidence that “a reasonable mind might accept as adequate to support a

13 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, 14 substantial evidence equates to “more than a mere scintilla[,] but less than a 15 preponderance.” Id. (quotation and citation omitted). In determining whether this 16 standard has been satisfied, a reviewing court must consider the entire record as a

17 whole rather than searching for supporting evidence in isolation. Id. 18 In reviewing a denial of benefits, a district court may not substitute its 19 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152,

20 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 1 rational interpretation, [the court] must uphold the ALJ’s findings if they are 2 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674

3 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an 4 ALJ’s decision on account of an error that is harmless.” Id. An error is harmless 5 “where it is inconsequential to the [ALJ’s] ultimate nondisability determination.”

6 Id. at 1115 (quotation and citation omitted). The party appealing the ALJ’s 7 decision generally bears the burden of establishing that it was harmed. Shinseki v. 8 Sanders, 556 U.S. 396, 409-10 (2009).

10 A claimant must satisfy two conditions to be considered “disabled” within 11 the meaning of the Social Security Act. First, the claimant must be “unable to 12 engage in any substantial gainful activity by reason of any medically determinable

13 physical or mental impairment which can be expected to result in death or which 14 has lasted or can be expected to last for a continuous period of not less than twelve 15 months.” 42 U.S.C. § 423(d)(1)(A). Second, the claimant’s impairment must be 16 “of such severity that he is not only unable to do his previous work[,] but cannot,

17 considering his age, education, and work experience, engage in any other kind of 18 substantial gainful work which exists in the national economy.” 42 U.S.C. § 19 423(d)(2)(A).

20 1 The Commissioner has established a five-step sequential analysis to 2 determine whether a claimant satisfies the above criteria. See 20 C.F.R. §

3 404.1520(a)(4)(i)–(v). At step one, the Commissioner considers the claimant’s 4 work activity. 20 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in 5 “substantial gainful activity,” the Commissioner must find that the claimant is not

6 disabled. 20 C.F.R. § 404.1520(b). 7 If the claimant is not engaged in substantial gainful activities, the analysis 8 proceeds to step two. At this step, the Commissioner considers the severity of the 9 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers

10 from “any impairment or combination of impairments which significantly limits 11 [his or her] physical or mental ability to do basic work activities,” the analysis 12 proceeds to step three. 20 C.F.R. § 404.1520(c). If the claimant’s impairment

13 does not satisfy this severity threshold, however, the Commissioner must find that 14 the claimant is not disabled. Id. 15 At step three, the Commissioner compares the claimant’s impairment to 16 several impairments recognized by the Commissioner to be so severe as to

17 preclude a person from engaging in substantial gainful activity. 20 C.F.R. § 18 404.1520(a)(4)(iii). If the impairment is as severe, or more severe than one of the 19 enumerated impairments, the Commissioner must find the claimant disabled and

20 award benefits. 20 C.F.R. § 404.1520(d). 1 If the severity of the claimant’s impairment does meet or exceed the severity 2 of the enumerated impairments, the Commissioner must pause to assess the

3 claimant’s “residual functional capacity.” Residual functional capacity (“RFC”), 4 defined generally as the claimant’s ability to perform physical and mental work 5 activities on a sustained basis despite his or her limitations (20 C.F.R. §

6 404.1545(a)(1)), is relevant to both the fourth and fifth steps of the analysis. 7 At step four, the Commissioner considers whether, in view of the claimant’s 8 RFC, the claimant is capable of performing work that he or she has performed in 9 the past (“past relevant work”). 20 C.F.R. § 404.1520(a)(4)(iv). If the claimant is

10 capable of performing past relevant work, the Commissioner must find that the 11 claimant is not disabled. 20 C.F.R. § 404.1520(f).

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