Hamlett v. Kijakazi, Commissioner of Social Security

CourtDistrict Court, N.D. California
DecidedSeptember 17, 2024
Docket3:23-cv-05552
StatusUnknown

This text of Hamlett v. Kijakazi, Commissioner of Social Security (Hamlett v. Kijakazi, Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamlett v. Kijakazi, Commissioner of Social Security, (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 T.H., Case No. 23-cv-05552-LB

12 Plaintiff, AMENDED ORDER REMANDING 13 v. FOR FURTHER ADMINISTRATIVE PROCEEDINGS 14 KILOLO KIJAKAZI, et al., Re: ECF Nos. 26, 28 15 Defendants. 16 17 INTRODUCTION 18 The plaintiff, T.H., seeks judicial review of a final decision by the Commissioner of the Social 19 Security Administration denying her claim for supplemental security income (SSI)1 under Title II 20 and Title XVI of the Social Security Act (SSA).2 This is her second petition to this court and 21 follows a previous remand to the agency.3 The plaintiff filed an opening brief in support of 22 remand, the Commissioner filed a brief, and the plaintiff filed a reply. Under Civil Local Rule 16- 23 24 25 1 The court filed this amended order because the plaintiff’s application, while filed in March 2017, was 26 filed before the March 27, 2017, effective date of the new regulations. 27 2 Compl. – ECF No. 1; Br. – ECF No. 26 at 7. Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. 1 5, the matter is submitted for decision by this court without oral argument. All parties consented to 2 magistrate-judge jurisdiction.4 The court remands for further proceedings. 3 4 STATEMENT 5 The court assumes familiarity with the record and incorporates by reference the procedural 6 history outlined in its prior order. After this court’s remand, the ALJ held a hearing on December 7 7, 2022, and heard testimony from the plaintiff and vocational expert (VE) Lizet Campos.5 It was 8 held telephonically due to the COVID-19 pandemic.6 The ALJ issued an unfavorable decision on 9 August 7, 2023.7 The plaintiff appealed pursuant to 42 U.S.C. § 405(g). The court also assumes 10 familiarity with the record and incorporates by reference the medical-evidence summaries and 11 summary of the June 7, 2019, administrative hearing provided in its prior order. The next sections 12 summarize the most recent administrative hearing and findings. 13 14 1. Medical Records 15 The plaintiff challenges the ALJ’s evaluation of medical-opinion evidence.8 The order 16 summarizes the relevant records in the analysis, below. 17 18 2. December 7, 2022, Administrative Hearing 19 2.1 The Plaintiff’s Testimony 20 The ALJ questioned the plaintiff, who had a non-attorney representative.9 Since the June 7, 2019, 21 administrative hearing, the plaintiff testified that she had worked “taking care of school age children” 22

23 4 Consents – ECF Nos. 7, 10. 24 5 Administrative Record 556. Administrative Record (AR) citations refer to the page numbers in the bottom right-hand corner of the AR. 25 6 Id. at 558. 26 7 Id. at 532. 27 8 Br. – ECF No. 26 at 7–8 (¶¶ 1–5). Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated pages at the top of documents. 1 but that the job “only lasted a few months” because of the COVID-19 pandemic.10 She testified that 2 she experiences ataxia and that it “affects [her] upper extremities and [her] lower limbs,” primarily 3 her right leg.11 She further testified that she could resume her prior job “if the kids could take care of 4 themselves” and if she didn’t have to bend, lift, or stoop.12 She indicated that her career was initially 5 in nursing but that she couldn’t perform nursing work anymore because of her hand.13 Finally, she 6 testified that she had not engaged in any sort of community or volunteer activities.14 7 2.2 The VE’s Testimony 8 The VE testified that the plaintiff’s prior work experience included working as a nurse 9 assistant (DOT 355. 674-014), home attendant, and child monitor (DOT 301. 677-010).15 The first 10 hypothetical was a person who could lift or carry twenty pounds occasionally, ten pounds 11 frequently, could stand, walk or sit six hours out of an eight-hour workday, could push or pull as 12 much as she could lift or carry, could occasionally stoop and occasionally climb, and could 13 frequently balance, kneel, crouch, and crawl. The person could not work around concentrated 14 exposures to vibrations, unprotected heights or dangerous, moving mechanical parts. She could 15 not work around concentrated exposures to extreme cold. She could occasionally reach overhead 16 with her left upper extremity and could lift overhead with her right upper extremity.16 The VE 17 testified that the hypothetical person could work as a school-bus monitor (DOT 372. 667-042), a 18 shipping and receiving weigher (DOT 222. 387-074), and a cashier (DOT 211. 462-010).17 The 19 ALJ asked the VE whether those same jobs would be available or others would be available “if a 20 person needed to have the ability to alternate between sitting or standing, as needed, so long as she 21 22 23 10 Id. at 566. 11 Id. at 569. 24 12 Id. at 570. 25 13 Id. 26 14 Id. at 571. 15 Id. at 573–74. 27 16 Id. at 574. 1 is not rendered off task and does not leave the work station.”18 The VE responded that the person 2 could work as a silver wrapper (DOT 318. 687-018). She further testified that the other jobs would 3 be eroded at fifty percent.19 The ALJ asked whether any of these jobs required the person to lift 4 more than ten pounds, and the VE testified that such a requirement would eliminate the silver 5 wrapper job and the fifty percent erosion would still apply to the cashier position and school bus 6 monitor position.20 The ALJ asked the VE whether a person could be off task fifteen percent of the 7 time, and the VE testified that it would render the person unemployable.21 Finally, the ALJ asked 8 whether any of the skills from the plaintiff’s prior work as a nursing assistant could be transferred 9 to other sedentary jobs, and the VE testified that they could not be transferred.22 10 11 3. ALJ Findings 12 At step one, the ALJ found that the plaintiff met the insured-status requirement of the SSA 13 through September 30, 2017, and that she had engaged in substantial gainful activity between June 14 and December 2020.23 15 At step two, the ALJ found that the plaintiff had the following severe impairments: obesity, 16 degenerative disc disease of the cervical and lumbar spine, hypertension, degenerative joint 17 disease of the left shoulder with possible bicipital tendonitis, and mild to moderate osteoarthritis of 18 the right knee.24 19 At step three, the ALJ found that the plaintiff did not have an impairment or combination of 20 impairments that met or medically equaled the severity of one of the listed impairments in 20 21 C.F.R., §§ 404.1520(d), 404.1525, 404.1526, 416.920(d), 416.925 and 416.926.25 22 23 18 Id. at 577. 19 Id. at 577–78. 24 20 Id. at 578–79. 25 21 Id. at 579–80. 26 22 Id. at 580. 23 Id. at 538. 27 24 Id. 1 Before reaching step four, the ALJ found that the plaintiff had a residual-functional capacity 2 (RFC) to perform light work.26 The ALJ limited the plaintiff’s RFC as follows:

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Bluebook (online)
Hamlett v. Kijakazi, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamlett-v-kijakazi-commissioner-of-social-security-cand-2024.