Hanna v. Commissioner of Social Security

CourtDistrict Court, S.D. California
DecidedJanuary 4, 2023
Docket3:22-cv-02043
StatusUnknown

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

Bluebook
Hanna v. Commissioner of Social Security, (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JALAL H., Case No.: 3:22-cv-02043-AHG 12 Plaintiff, ORDER GRANTING MOTION FOR LEAVE TO PROCEED IN FORMA 13 v. PAUPERIS 14 COMMISSIONER OF SOCIAL SECURITY, [ECF No. 2] 15 Defendant. 16 17 18 19 20 On December 23, 2022, Plaintiff Jalal H. (“Plaintiff”) brought this action against the 21 Commissioner of Social Security, seeking judicial review of the Commissioner’s final 22 administrative decision denying his application for Social Security Supplemental Security 23 Income Disability Benefits for lack of disability. ECF No. 1. Along with his Complaint, 24 Plaintiff also filed a Motion for Leave to Proceed in forma pauperis (“IFP”) under 28 25 U.S.C. § 1915. ECF No. 2. 26 I. LEGAL STANDARD 27 A motion to proceed IFP presents two issues for the Court’s consideration. First, the 28 Court must determine whether an applicant properly shows an inability to pay the 1 $402 civil filing fee required by this Court. See 28 U.S.C. §§ 1914(a), 1915(a). To that 2 end, an applicant must also provide the Court with a signed affidavit “that includes a 3 statement of all assets[,] which shows inability to pay initial fees or give security.” CivLR 4 3.2(a). Second, § 1915(e)(2)(B)(ii) requires the Court to evaluate whether an applicant’s 5 complaint sufficiently states a claim upon which relief may be granted. See Lopez v. Smith, 6 203 F.3d 1122, 1127 (9th Cir. 2000) (“1915(e) not only permits but requires a district court 7 to dismiss an in forma pauperis complaint that fails to state a claim.”). 8 II. DISCUSSION 9 A. Motion to Proceed IFP 10 An applicant need not be completely destitute to proceed IFP, but he must adequately 11 prove his indigence. Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339–40 12 (1948). An adequate affidavit should “allege[] that the affiant cannot pay the court costs 13 and still afford the necessities of life.” Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th 14 Cir. 2015) (citing Adkins, 335 U.S. at 339). No exact formula is “set forth by statute, 15 regulation, or case law to determine when someone is poor enough to earn IFP status.” 16 Escobedo, 787 F.3d at 1235. Consequently, courts must evaluate IFP requests on a case- 17 by-case basis. See id. at 1235–36 (declining to implement a general benchmark of “twenty 18 percent of monthly household income”); see also Cal. Men’s Colony v. Rowland, 939 F.2d 19 854, 858 (9th Cir. 1991) (requiring that district courts evaluate indigency based upon 20 available facts and by exercise of their “sound discretion”), rev’d on other grounds, 506 21 U.S. 194 (1993); Venable v. Meyers, 500 F.2d 1215, 1216 (9th Cir. 1974). 22 An adequate affidavit should also state supporting facts “with some particularity, 23

24 25 1 In addition to the $350 statutory fee, civil litigants must pay an additional administrative fee of $52. See 28 U.S.C. § 1914(a); UNITED STATES COURTS, DISTRICT COURT 26 MISCELLANEOUS FEE SCHEDULE § 14 (effective Dec. 1, 2020), 27 https://www.uscourts.gov/services-forms/fees/district-court-miscellaneous-fee-schedule. The additional $52 administrative fee does not apply to persons granted leave to proceed 28 1 definiteness and certainty.” United States v. McQuade, 647 F.2d 938, 940 (9th Cir. 1981) 2 (citing Jefferson v. United States, 277 F.2d 723, 725 (9th Cir. 1960)). The Court should not 3 grant IFP status to an applicant who is “financially able, in whole or in material part, to 4 pull his own oar.” Temple v. Ellerthorpe, 586 F. Supp. 848, 850 (D.R.I. 1984); see also 5 Alvarez v. Berryhill, No. 18cv2133-W-BGS, 2018 WL 6265021, at *1 (S.D. Cal. Oct. 1, 6 2018) (noting that courts often reject IFP applications when applicants “can pay the filing 7 fee with acceptable sacrifice to other expenses”). Additionally, courts have discretion to 8 make a factual inquiry and to deny a motion to proceed IFP when the moving party is 9 “unable, or unwilling, to verify their poverty.” McQuade, 647 F.2d at 940. 10 Here, Plaintiff states in his affidavit that he receives $2,000.00 per month in public 11 assistance, has $180.00 in his checking account, has no valuable assets other than his 2001 12 Chevrolet Silverado, and he and his spouse2 have no other source of income. ECF No. 2 at 13 1–3. Plaintiff’s affidavit illustrates that his monthly income barely exceeds his monthly 14 expenses of $1,924.00 for rent, utilities, groceries, clothing, gas, car insurance, and 15 household goods. Id. at 2–5. Plaintiff explains that he lived with his wife and two children 16 in his car; they now live in a trailer but are still struggling to subsist on food stamps. Id. at 17 5. Considering the information in the affidavit,3 the Court finds that Plaintiff has 18 sufficiently shown an inability to pay the $402 filing fee under § 1915(a). 19 20 21 2 Compare Vimegnon v. Or. Health & Sci. Univ., No. 3:16-cv-2304-HZ, 2017 WL 111309, 22 at *2 (D. Or. Jan. 9, 2017) (collecting cases that find spouses’ income to be particularly relevant in IFP applications) with ECF No. 2 at 2 (representing that Plaintiff’s spouse has 23 not been employed for the last two years and does not have any other sources of income). 24 3 The Court also notes that the 2022 federal poverty guideline for a family of four is 25 $27,750, which is more than the $24,000 in annual welfare benefits Plaintiff receives. See U.S. DEPT. OF HEALTH & HUMAN SERV., U.S. FEDERAL POVERTY GUIDELINES, 26 https://aspe.hhs.gov/topics/poverty-economic-mobility/poverty-guidelines; see also Burk 27 v. Comm’r of Soc. Sec. Admin., No. CV-22-1626-PHX-DGC, 2022 U.S. Dist. LEXIS 189208, at *2–3 (D. Ariz. Oct. 17, 2022) (collecting cases where courts considered federal 28 1 B. Screening under 28 U.S.C. 1915(e) 2 As discussed above, every complaint filed pursuant to the IFP provisions of 28 3 U.S.C. § 1915 is subject to a mandatory screening by the Court under Section 4 1915(e)(2)(B). Lopez, 203 F.3d at 1127. Under that subprovision, the Court must dismiss 5 complaints that are frivolous or malicious, fail to state a claim on which relief may be 6 granted, or seek monetary relief from defendants who are immune from such relief. See 28 7 U.S.C. § 1915(e)(2)(B). Social Security appeals are not exempt from this screening 8 requirement. See Hoagland v. Astrue, No. 1:12-cv-00973-SMS, 2012 WL 2521753, at *1 9 (E.D. Cal. June 28, 2012) (“Screening is required even if the plaintiff pursues an appeal of 10 right, such as an appeal of the Commissioner’s denial of social security disability benefits 11 [under 42 U.S.C. 405(g)].”); see also Calhoun v. Stahl,

Related

Adkins v. E. I. DuPont De Nemours & Co.
335 U.S. 331 (Supreme Court, 1948)
Jesse J. Calhoun v. Donald N. Stahl James Brazelton
254 F.3d 845 (Ninth Circuit, 2001)
Temple v. Ellerthorpe
586 F. Supp. 848 (D. Rhode Island, 1984)
Maria Escobedo v. Apple American Group
787 F.3d 1226 (Ninth Circuit, 2015)
Lopez v. Smith
203 F.3d 1122 (Ninth Circuit, 2000)

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Hanna v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hanna-v-commissioner-of-social-security-casd-2023.