Greenwalt v. Commissioner of Social Security

CourtDistrict Court, E.D. Washington
DecidedMarch 20, 2020
Docket2:19-cv-00044
StatusUnknown

This text of Greenwalt v. Commissioner of Social Security (Greenwalt v. Commissioner of Social Security) 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
Greenwalt v. Commissioner of Social Security, (E.D. Wash. 2020).

Opinion

2 FILED IN THE EASTERU N. S D. I SD TI RS IT CR TI C OT F C WO AU SR HT I NGTON 3 Mar 20, 2020

4 SEAN F. MCAVOY, CLERK

5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 RENEE ANN G., NO: 2:19-CV-44-FVS 8 Plaintiff, ORDER DENYING PLAINTIFF’S 9 v. MOTION FOR SUMMARY JUDGMENT AND GRANTING 10 ANDREW M. SAUL, DEFENDANT’S MOTION FOR COMMISSIONER OF SOCIAL SUMMARY JUDGMENT 11 SECURITY,1

12 Defendant.

13 14 BEFORE THE COURT are the parties’ cross-motions for summary judgment. 15 ECF Nos. 12, 13. This matter was submitted for consideration without oral 16

17 1 Andrew M. Saul is now the Commissioner of the Social Security 18 Administration. Accordingly, the Court substitutes Andrew M. Saul as the 19 Defendant and directs the Clerk to update the docket sheet. See Fed. R. Civ. P. 20 25(d). 21 1 argument. Plaintiff is represented by attorney Chad Hatfield. Defendant is 2 represented by Special Assistant United States Attorney Michael Howard. The 3 Court, having reviewed the administrative record and the parties’ briefing, is fully 4 informed. For the reasons discussed below, Plaintiff’s Motion, ECF No. 12, is

5 denied and Defendant’s Motion, ECF No. 13, is granted. 6 JURISDICTION 7 Plaintiff Renee Ann G.2 (Plaintiff), filed for child’s insurance benefits3 on

8 May 26, 2016, alleging an onset date of November 17, 2009. Tr. 168-71. Benefits 9 were denied initially, Tr. 91-97, and upon reconsideration, Tr. 99-105. Plaintiff 10 appeared at a hearing before an administrative law judge (ALJ) on December 20, 11 2017. Tr. 31-65. On March 5, 2018, the ALJ issued an unfavorable decision, Tr.

13 2In the interest of protecting Plaintiff’s privacy, the Court will use Plaintiff’s first 14 name and last initial, and, subsequently, Plaintiff’s first name only, throughout this 15 decision. 16 3 An adult disabled before age 22 may be eligible for “child’s benefits” if a parent 17 is deceased or starts receiving retirement or disability benefits. These are called 18 “child’s benefits” because they are paid on a parent’s Social Security earnings

19 record. The adult child must be unmarried, age 18 or older, have a disability that 20 started before age 22, and meet the definition of disability for adults. See 20 21 U.S.C. § 402(d). 1 12-30, and on November 29, 2018, the Appeals Council denied review. Tr. 1-6. 2 The matter is now before this Court pursuant to 42 U.S.C. § 405(g). 3 BACKGROUND 4 The facts of the case are set forth in the administrative hearing and transcripts,

5 the ALJ’s decision, and the briefs of Plaintiff and the Commissioner, and are 6 therefore only summarized here. 7 Plaintiff was born in 1988 and was 29 years old at the time of the hearing. Tr.

8 168. She graduated from high school, has an A.A. in technical education, and is a 9 licensed cosmetologist. Tr. 384. She worked as a cosmetologist for three months. 10 Tr. 49-50. She cried at work every day because her boss was mean to her and she 11 was eventually fired. Tr. 50-51. She testified that she has headaches every day and

12 three times a week they are so bad that she has to lie down for the day. Tr. 55. 13 Sometimes she has to go to the hospital for nausea and pain medicine. Tr. 55. 14 STANDARD OF REVIEW

15 A district court’s review of a final decision of the Commissioner of Social 16 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 17 limited; the Commissioner’s decision will be disturbed “only if it is not supported by 18 substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158

19 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a reasonable 20 mind might accept as adequate to support a conclusion.” Id. at 1159 (quotation and 21 citation omitted). Stated differently, substantial evidence equates to “more than a 1 mere scintilla[,] but less than a preponderance.” Id. (quotation and citation omitted). 2 In determining whether the standard has been satisfied, a reviewing court must 3 consider the entire record as a whole rather than searching for supporting evidence in 4 isolation. Id.

5 In reviewing a denial of benefits, a district court may not substitute its 6 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 1156 7 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one

8 rational interpretation, [the court] must uphold the ALJ’s findings if they are 9 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 10 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an ALJ’s 11 decision on account of an error that is harmless.” Id. An error is harmless “where it

12 is inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1115 13 (quotation and citation omitted). The party appealing the ALJ’s decision generally 14 bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S.

15 396, 409-10 (2009). 16 FIVE-STEP EVALUATION PROCESS 17 A claimant must satisfy two conditions to be considered “disabled” within the 18 meaning of the Social Security Act. First, the claimant must be “unable to engage in

19 any substantial gainful activity by reason of any medically determinable physical or 20 mental impairment which can be expected to result in death or which has lasted or 21 can be expected to last for a continuous period of not less than twelve months.” 42 1 U.S.C. §§ 423(d)(1)(A). Second, the claimant’s impairment must be “of such 2 severity that he is not only unable to do his previous work[,] but cannot, considering 3 his age, education, and work experience, engage in any other kind of substantial 4 gainful work which exists in the national economy.” 42 U.S.C. § 423(d)(2)(A).

5 The Commissioner has established a five-step sequential analysis to determine 6 whether a claimant satisfies the above criteria. See 20 C.F.R. § 404.1520(a)(4)(i)- 7 (v). At step one, the Commissioner considers the claimant’s work activity. 20

8 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in “substantial gainful 9 activity,” the Commissioner must find that the claimant is not disabled. 20 C.F.R. § 10 404.1520(b). 11 If the claimant is not engaged in substantial gainful activity, the analysis

12 proceeds to step two. At this step, the Commissioner considers the severity of the 13 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers from 14 “any impairment or combination of impairments which significantly limits [his or

15 her] physical or mental ability to do basic work activities,” the analysis proceeds to 16 step three. 20 C.F.R. §

Related

Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Bartlett v. Strickland
556 U.S. 1 (Supreme Court, 2009)
Turner v. Commissioner of Social Security
613 F.3d 1217 (Ninth Circuit, 2010)
United States v. Conway
81 F.3d 15 (First Circuit, 1996)

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Greenwalt v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greenwalt-v-commissioner-of-social-security-waed-2020.