Haas v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedMay 27, 2025
Docket2:24-cv-03212
StatusUnknown

This text of Haas v. Commissioner of Social Security Administration (Haas 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
Haas v. Commissioner of Social Security Administration, (D. Ariz. 2025).

Opinion

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

9 Clarence Haas, No. CV-24-03212-PHX-JAT

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court is Plaintiff Clarence Haas’s (“Plaintiff”) appeal from the 16 Commissioner of the Social Security Administration’s (“SSA,” “Commissioner,” or 17 “Defendant”) denial of Social Security benefits. The appeal is fully briefed (Docs. 11, 15, 18 16), and the Court now rules. 19 I. BACKGROUND 20 A. Factual Overview 21 Plaintiff was 50 years old on his alleged disability onset date of February 7, 2020. 22 (Doc. 11 at 2). He has past relevant work as a Deliverer Outside. (Doc. 9-3 at 39). On 23 December 8, 2021, Plaintiff filed a Title II application for a period of disability and 24 disability insurance benefits. (Id. at 24). Denial of Plaintiff’s claim occurred initially on 25 April 17, 2023, and upon reconsideration on June 28, 2023. (Id.) Plaintiff filed a written 26 request for a hearing before an administrative law judge (“ALJ”), which occurred by 27 telephone on November 3, 2023. (Id.) An impartial vocational expert (VE) also appeared 28 and testified in the hearing. (Id.) The ALJ issued a decision on March 28, 2024, finding 1 Plaintiff was not disabled under Section 1614(a)(3)(A) of the Social Security Act. (Id. at 2 41). On October 2, 2024, the SSA Appeals Council denied Plaintiff’s request for review of 3 the ALJ’s decision and adopted the ALJ’s decision as final. (Doc. 9-3 at 2). 4 B. The SSA’s Five-Step Evaluation Process 5 To qualify for Social Security Disability Insurance benefits, a claimant must show 6 that he “is under a disability.” 42 U.S.C. § 423(a)(1)(E). To be “under a disability,” the 7 claimant must be unable to engage in “substantial gainful activity” due to any medically 8 determinable physical or mental impairment. Id. § 423(d)(1). The impairment must be of 9 such severity that the claimant cannot do his previous work or any other substantial gainful 10 work within the national economy. Id. § 423(d)(2). The SSA has created a five-step 11 sequential evaluation process for determining whether an individual is disabled. See 20 12 C.F.R. § 404.1520(a)(1). The steps are followed in order, and each step is potentially 13 dispositive. See id. § 404.1520(a)(4). 14 At Step One, the ALJ determines whether the claimant is engaging in “substantial 15 gainful activity.” Id. § 404.1520(a)(4)(i). “Substantial gainful activity” is work activity that 16 is (1) “substantial,” i.e., doing “significant physical or mental activities”; and (2) “gainful,” 17 i.e., usually done “for pay or profit.” 20 C.F.R. § 416.972(a)–(b). If the claimant is engaging 18 in substantial gainful work activity, the ALJ will find the claimant is not disabled. Id. § 19 404.1520(a)(4)(i). 20 At Step Two, the ALJ determines whether the claimant has “a severe medically 21 determinable physical or mental impairment” or severe “combination of impairments.” Id. 22 § 404.1520(a)(4)(ii). To be “severe,” the claimant’s impairment must “significantly limit” 23 the claimant’s “physical or mental ability to do basic work activities.” Id. § 404.1520(c). 24 If the claimant does not have a severe impairment or combination of impairments, the ALJ 25 will find the claimant is not disabled. Id. § 404.1520(a)(4)(ii). 26 At Step Three, the ALJ determines whether the claimant’s impairment(s) “meets or 27 equals” an impairment listed in Appendix 1 to Subpart P of 20 C.F.R. Part 404. Id. § 28 404.1520(a)(4)(iii). If so, the ALJ will find the claimant is disabled, but if not, the ALJ 1 must assess the claimant’s “residual functional capacity” (“RFC”) before proceeding to 2 Step Four. Id. §§ 404.1520(a)(4)(iii), 404.1520(e). The claimant’s RFC is his ability 3 perform physical and mental work activities “despite his limitations,” based on all relevant 4 evidence in the case record. Id. § 404.1545(a)(1). To determine RFC, the ALJ must 5 consider all the claimant’s impairments, including those that are not “severe,” and any 6 related symptoms that “affect what [the claimant] can do in a work setting.” Id. §§ 7 404.1545(a)(1)–(2). 8 At Step Four, the ALJ determines whether the claimant has the RFC to perform the 9 physical and mental demands of “his past relevant work.” Id. §§ 404.1520(a)(4)(iv), 10 404.1520(e). “Past relevant work” is work the claimant has “done within the past 15 years, 11 that was substantial gainful activity.” Id. § 404.1560(b)(1). If the claimant has the RFC to 12 perform his past relevant work, the ALJ will find the claimant is not disabled. Id. § 13 404.1520(a)(4)(iv). If the claimant cannot perform his past relevant work, the ALJ will 14 proceed to Step Five in the sequential evaluation process. 15 At Step Five, the final step, the ALJ considers whether the claimant “can make an 16 adjustment to other work,” considering his RFC, age, education, and work experience. Id. 17 § 404.1520(a)(v). If so, the ALJ will find the claimant not disabled. Id. If the claimant 18 cannot make this adjustment, the ALJ will find the opposite. Id. 19 C. The ALJ’s Application of the Factors 20 Here, at Step One, the ALJ concluded that the record established that Plaintiff had 21 “not engaged in substantial gainful activity since February 7, 2020, the alleged onset date.” 22 (Doc. 9-3 at 26). 23 At Step Two, the ALJ determined that Plaintiff had the following severe 24 impairments: “scoliosis, right shoulder rotator cuff tendinosis, bilateral hip arthritis, 25 migraine headaches, and obesity.” (Id. at 27). 26 At Step Three, the ALJ found that Plaintiff did not have any impairment or 27 combination of impairments that met or medically equaled a listed impairment in Appendix 28 1 to Subpart P of 20 C.F.F. Part 404. (Id. at 32). Subsequently, the ALJ determined that 1 Plaintiff had the RFC to perform light work as defined in 20 CFR 404.1567(b), except that 2 Plaintiff: can lift and carry 20 pounds occasionally, 10 pounds 3 frequently, stand and walk for 6 hours in an 8-hour day, and sit 4 for 6 hours in an 8-hour day. [He] can frequently climb ramps and stairs, but occasionally climb ladders or scaffolds. [He] can 5 frequently reach with the right upper extremity and must avoid 6 concentrated exposure to hazards. (Id. at 34). 7 At Step Four, the ALJ concluded that Plaintiff capable of performing past relevant 8 work as a Deliverer Outside, and he also concluded that this work did not require 9 performing work-related activities that were precluded by Plaintiff’s RFC. (Id. at 39). At 10 Step Five, the ALJ found that Plaintiff could make sufficient adjustments to perform other 11 work that exists in significant numbers in the national economy given his age, education, 12 work experience, and RFC. (Id.) Examples of such jobs included Marker, Cleaner 13 Housekeeping, and Inspector Hand Packager. (Id. at 40). Accordingly, the ALJ concluded 14 that Plaintiff was not disabled, “as defined in the Social Security Act, from February 7, 15 2020, through the date of [the] decision.” (Id. at 41). 16 II. LEGAL STANDARD 17 In determining whether to reverse an ALJ’s decision, the district court reviews only 18 those issues raised by the party challenging the decision. Lewis v. Apfel, 236 F.3d 503, 517 19 n.13 (9th Cir. 2001).

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Haas v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haas-v-commissioner-of-social-security-administration-azd-2025.