Hathaway v. Berryhill

CourtDistrict Court, D. Nevada
DecidedFebruary 20, 2020
Docket3:19-cv-00135
StatusUnknown

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

Bluebook
Hathaway v. Berryhill, (D. Nev. 2020).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 4 PAULETTE DAWN HATHAWAY, 3:19-cv-00135-CLB 5 Plaintiff, 6 v. ORDER 7 ANDREW SAUL1, Acting Commissioner of Social Security, 8 Defendant. 9

10 This case involves the judicial review of an administrative action by the 11 Commissioner of Social Security (“Commissioner”) denying Paulette Dawn Hathaway’s 12 (“Hathaway”) application for disability insurance benefits and supplemental security 13 income pursuant to Titles II and XVI of the Social Security Act. Currently pending before 14 the court is Hathaway’s motion for reversal or remand. (ECF No. 16.) In this motion, 15 Hathaway seeks the reversal of the administrative decision and remand for an award of 16 benefits. (Id.) The Commissioner filed a response and cross-motion to affirm (ECF No. 17 18/19), and Hathaway filed a reply (ECF No. 20). Having reviewed the pleadings, 18 transcripts, and the Administrative Record (“AR”), the court concludes the Commissioner’s 19 finding that Hathaway could perform past relevant work was supported by substantial 20 evidence. Therefore, the court denies Hathaway’s motion for remand, (ECF No. 16), and 21 grants the Commissioner’s cross-motion to affirm, (ECF No. 18). 22 I. STANDARDS OF REVIEW 23 A. Judicial Standard of Review 24 This court’s review of administrative decisions in social security disability benefits 25 cases is governed by 42 U.S.C. § 405(g). See Akopyan v. Barnhart, 296 F.3d 852, 854 26

27 1 Andrew Saul is now the Commissioner of Social Security and is automatically 28 1 (9th Cir. 2002). Section 405(g) provides that “[a]ny individual, after any final decision of 2 the Commissioner of Social Security made after a hearing to which he was a party, 3 irrespective of the amount in controversy, may obtain a review of such decision by a civil 4 action ... brought in the district court of the United States for the judicial district in which 5 the plaintiff resides.” The court may enter, “upon the pleadings and transcript of the record, 6 a judgment affirming, modifying, or reversing the decision of the Commissioner of Social 7 Security, with or without remanding the cause for a rehearing.” Id. 8 The court must affirm an Administrative Law Judge’s (“ALJ”) determination if it is 9 based on proper legal standards and the findings are supported by substantial evidence 10 in the record. Stout v. Comm’r Soc. Sec. Admin., 454 F.3d 1050, 1052 (9th Cir. 2006); 11 see also 42 U.S.C. § 405(g) (“findings of the Commissioner of Social Security as to any 12 fact, if supported by substantial evidence, shall be conclusive”). “Substantial evidence is 13 more than a mere scintilla but less than a preponderance.” Bayliss v. Barnhart, 427 F.3d 14 1211, 1214 n.1 (9th Cir. 2005) (internal quotation marks and citation omitted). “It means 15 such relevant evidence as a reasonable mind might accept as adequate to support a 16 conclusion.” Richardson v. Perales, 402 U.S. 389, 401, 91 S.Ct. 1420, 28 L.Ed.2d 842 17 (1971) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 18 L.Ed. 126 (1938)); see also Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). 19 To determine whether substantial evidence exists, the court must look at the 20 administrative record as a whole, weighing both the evidence that supports and 21 undermines the ALJ’s decision. Orteza v. Shalala, 50 F.3d 748, 749 (9th Cir. 1995) 22 (citation omitted). Under the substantial evidence test, a court must uphold the 23 Commissioner’s findings if they are supported by inferences reasonably drawn from the 24 record. Batson v. Comm’r, Soc. Sec. Admin., 359 F.3d 1190, 1193 (9th Cir. 2004). 25 “However, if evidence is susceptible of more than one rational interpretation, the decision 26 of the ALJ must be upheld.” Orteza, 50 F.3d at 749 (citation omitted). The ALJ alone is 27 responsible for determining credibility and for resolving ambiguities. Meanel v. Apfel, 172 28 F.3d 1111, 1113 (9th Cir. 1999). 1 It is incumbent on the ALJ to make specific findings so that the court does not 2 speculate as to the basis of the findings when determining if substantial evidence supports 3 the Commissioner’s decision. The ALJ’s findings should be as comprehensive and 4 analytical as feasible and, where appropriate, should include a statement of subordinate 5 factual foundations on which the ultimate factual conclusions are based, so that a 6 reviewing court may know the basis for the decision. See Gonzalez v. Sullivan, 914 F.2d 7 1197, 1200 (9th Cir. 1990). 8 B. Standards Applicable to Disability Evaluation Process 9 The individual seeking disability benefits bears the initial burden of proving 10 disability. Roberts v. Shalala, 66 F.3d 179, 182 (9th Cir. 1995). To meet this burden, the 11 individual must demonstrate the “inability to engage in any substantial gainful activity by 12 reason of any medically determinable physical or mental impairment which can be 13 expected ... to last for a continuous period of not less than 12 months.” 42 U.S.C. § 14 423(d)(1)(A). More specifically, the individual must provide “specific medical evidence” in 15 support of her claim for disability. See 20 C.F.R. § 404.1514. If the individual establishes 16 an inability to perform her prior work, then the burden shifts to the Commissioner to show 17 that the individual can perform other substantial gainful work that exists in the national 18 economy. Reddick v. Chater, 157 F.3d 715, 721 (9th Cir. 1998). 19 The first step requires the ALJ to determine whether the individual is currently 20 engaging in substantial gainful activity (“SGA”). 20 C.F.R. §§ 404.1520(b), 416.920(b). 21 SGA is defined as work activity that is both substantial and gainful; it involves doing 22 significant physical or mental activities, usually for pay or profit. 20 C.F.R. §§ 404.1572(a)- 23 (b), 416.972(a)-(b). If the individual is currently engaging in SGA, then a finding of not 24 disabled is made. If the individual is not engaging in SGA, then the analysis proceeds to 25 the second step. 26 The second step addresses whether the individual has a medically determinable 27 impairment that is severe or a combination of impairments that significantly limits her from 28 performing basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).

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Hathaway v. Berryhill, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hathaway-v-berryhill-nvd-2020.