Gifford v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedMarch 30, 2024
Docket2:22-cv-01567
StatusUnknown

This text of Gifford v. Commissioner of Social Security Administration (Gifford 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
Gifford 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 Tiag Gifford, No. CV-22-01567-PHX-DJH

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Plaintiff Tiag Gifford (“Plaintiff”) seeks this Court’s review of the Social Security 16 Administration (“SSA”) Commissioner’s (the “Commissioner”) denial of his application 17 for Social Security Disability Insurance (“SSDI”) and Supplemental Security Income 18 (“SSI”) benefits. (Doc. 15 at 1). The matter is fully briefed. (Docs. 15; 17; 18). Upon 19 review of the briefs and the Administrative Record (Docs. 10 & 11, “AR”), the Court 20 affirms in part and reverses in part. 21 I. Background 22 Plaintiff initially applied for SSI and SSDI benefits under the Social Security Act 23 (“the Act”) in May of 2015 and alleged a disability onset date of March 29, 2015. 24 (AR at 23). These claims were denied by the Commissioner and on an Admirative Law 25 Judge (“ALJ”) concluded that Plaintiff was not disable under the Act. (Id. at 23–24). 26 Plaintiff filed a complaint for judicial review and the Commissioner stipulated to a remand. 27 (Id. at 1697). This Court remanded the case to the Commissioner and a second hearing 28 was conducted. (Id.) The ALJ found in its September 21, 2021, decision that Plaintiff was 1 disabled from March 29, 2015, through February 15, 2017; but that medical improvement 2 occurred on February 16, 2017, related to Plaintiff’s ability to work. (Id. at 1680). To 3 determine whether Plaintiff was disabled, the ALJ used a five-step SSA process for 4 determining whether an individual is disabled. (Id. at 1681–82). To determine whether 5 Plaintiff continued to be disabled through the date of its decision, the ALJ utilized an eight- 6 step process developed for this purpose related to Title II claims. (Id. at 1682–84). 7 A. The ALJ’s Five-Step Process 8 To be eligible for Social Security benefits, a claimant must show an “inability to 9 engage in any substantial gainful activity by reason of any medically determinable physical 10 or mental impairment which can be expected to result in death or which has lasted or can 11 be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. 12 § 423(d)(1)(A); see also Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999). The ALJ 13 follows a five-step process1 to determine whether a claimant is disabled for purposes of the 14 Social Security Act (“the Act”): 15 The five-step process for disability determinations begins, at the first and 16 second steps, by asking whether a claimant is engaged in “substantial gainful activity” and considering the severity of the claimant’s impairments. 17 See 20 C.F.R. § 416.920(a)(4)(i)-(ii). If the inquiry continues beyond the 18 second step, the third step asks whether the claimant’s impairment or combination of impairments meets or equals a listing under 19 20 C.F.R. pt. 404, subpt. P, app. 1 and meets the duration requirement. 20 See id. § 416.920(a)(4)(iii). If so, the claimant is considered disabled and benefits are awarded, ending the inquiry. See id. If the process continues 21 beyond the third step, the fourth and fifth steps consider the claimant’s “residual functional capacity”[2] in determining whether the claimant can 22 still do past relevant work or make an adjustment to other work. 23 See id. § 416.920(a)(4)(iv)-(v). 24 Kennedy v. Colvin, 738 F.3d 1172, 1175 (9th Cir. 2013); see also 20 C.F.R. § 404.1520(a)– 25

26 1 The claimant bears the burden of proof on the first four steps, but the burden shifts to the Commissioner at step five. Tackett, 180 F.3d at 1098. 27 2 A claimant’s “residual functional capacity” is defined as their ability to do physical and 28 mental work activities on a sustained basis despite limitations from their impairments. See 20 C.F.R. §§ 404.1520(e), 416.920(e). 1 (g). If the ALJ determines no such work is available, the claimant is disabled. 2 Id. § 404.1520(a)(4)(v). 3 At the first and second steps, the ALJ concluded that Plaintiff had not engaged in 4 substantial gainful activity since his alleged disability onset date and that Plaintiff had the 5 following severe impairments: “status post femur fracture, status post sacral fracture, status 6 post lumbosacral fixation, status post right testicular disruption avulsion, degenerative disc 7 disease (DDD), and complex regional pain syndrome.” (AR at 1684). At the third step, 8 the ALJ concluded that Plaintiff did not have an impairment or combination of impairments 9 that met or medically equaled the severity of one of the listed impairments in 20 C.F.R. pt. 10 404, subpt. P, app. 1. (Id. at 1685). 11 At step four, the ALJ concluded that Plaintiff had the following residual functional 12 capacity (“RFC”) from March 29, 2015, through February 15, 2017: 13 [Plaintiff has the RFC] “to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a) except he could sit for 6 hours with normal 14 breaks and stand and/or walk for 2 hours with normal breaks during an 8- 15 hour day. He could lift and carry 10 pounds occasionally and 5 pounds frequently. He required the option to use a cane for ambulation. He could 16 have no exposure to hazards such as moving machinery and unprotected 17 heights. Due to his symptoms and treatment associated with his combined impairments, he would have missed work two to three times per month on 18 average. 19 (Id.) At step-five, the ALJ found that Plaintiff was unable to perform any past relevant 20 work or make an adjustment to other work. (Id. at 1693). In other words, Plaintiff was 21 disabled from March 29, 2015, through February 15, 2017. (See id.) However, utilizing 22 the Eight-Step Process, the ALJ concluded that Plaintiff was no longer disabled as of 23 February 16, 2017. (Id. at 1694). 24 B. The ALJ’s Eight-Step Process 25 The framework for determining whether a claimant continues to be disabled under 26 the Act entails an eight-step evaluation process for Title II claims and a seven-step 27 evaluation for Title XVI claims. See 20 C.F.R. §§ 404.1594(f), 416.994(b)(5). Plaintiff’s 28 application for benefits is a Title II application, therefore, the Eight-Step process applies. 1 (AR at 23). This district has summarized the framework as follows: 2 At step 1 of the Title II evaluation, the ALJ determines whether the claimant 3 is engaging in substantial gainful activity. 20 C.F.R. § 404.1594(f)(1). If so, the claimant is no longer disabled. Id. If not, the ALJ proceeds to step 2 4 (step 1 for the Title XVI evaluation). Id. § 404.1594(f)(2). 5 At step 2, the ALJ determines if the claimant has an impairment or 6 combination of impairment[s] which meets or equals the severity of an impairment listed in Appendix 1 to 20 C.F.R. § 404, subpart P. Id. If so, the 7 claimant is still disabled. Id. If not, the ALJ proceeds to step 3. 8 Id. § 404.1594(f)(3). 9 At step 3, the ALJ determines if there has been medical improvement as 10 shown by a decrease in medical severity. Id. If so, the ALJ proceeds to step 4. Id.

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