Heitschmidt v. Kijakazi

CourtDistrict Court, E.D. Washington
DecidedMay 26, 2022
Docket2:20-cv-00350
StatusUnknown

This text of Heitschmidt v. Kijakazi (Heitschmidt v. Kijakazi) 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
Heitschmidt v. Kijakazi, (E.D. Wash. 2022).

Opinion

1 2 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 3 May 26, 2022 4 SEAN F. MCAVOY, CLERK 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 MADISON H.,1 No. 2:20-cv-00350-MKD

8 Plaintiff, ORDER DENYING PLAINTIFF’S MOTION FOR SUMMARY 9 v. JUDGMENT AND GRANTING DEFENDANT’S MOTION FOR 10 KILOLO KIJAKAZI, ACTING SUMMARY JUDGMENT COMMISSIONER OF SOCIAL 11 SECURITY,2 ECF Nos. 18, 20, 26, 31

12 Defendant. 13

14 1 To protect the privacy of plaintiffs in social security cases, the undersigned 15 identifies them by only their first names and the initial of their last names. See 16 LCivR 5.2(c). 17 2 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 18 2021. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo 19 Kijakazi is substituted for Andrew M. Saul as the defendant in this suit. No further 20 action need be taken to continue this suit. See 42 U.S.C. § 405(g). 2 1 Before the Court are the parties’ cross-motions for summary judgment, ECF 2 Nos. 18, 20, along with Plaintiff’s supplemental motion for summary judgement,

3 ECF No. 26, and Plaintiff’s motion to strike the issue raised in the supplemental 4 motion, ECF No. 31. The Court, having reviewed the administrative record and 5 the parties’ briefing, is fully informed. For the reasons discussed below, the Court

6 denies Plaintiff’s motion for summary judgment, ECF No. 18, and grants 7 Defendant’s motion for summary judgment, ECF No. 20. Plaintiff’s supplemental 8 motion for summary judgement is denied as moot, ECF No. 26, and Plaintiff’s 9 motion to strike the issue, ECF No. 31, is granted.

10 JURISDICTION 11 The Court has jurisdiction over this case pursuant to 42 U.S.C. § 1383(c)(3). 12 STANDARD OF REVIEW

13 A district court’s review of a final decision of the Commissioner of Social 14 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 15 limited; the Commissioner’s decision will be disturbed “only if it is not supported 16 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153,

17 1158 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a 18 reasonable mind might accept as adequate to support a conclusion.” Id. at 1159 19 (quotation and citation omitted). Stated differently, substantial evidence equates to

20 “more than a mere scintilla[,] but less than a preponderance.” Id. (quotation and 2 1 citation omitted). In determining whether the standard has been satisfied, a 2 reviewing court must consider the entire record as a whole rather than searching

3 for supporting evidence in isolation. Id. 4 In reviewing a denial of benefits, a district court may not substitute its 5 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152,

6 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 7 rational interpretation, [the court] must uphold the ALJ’s findings if they are 8 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 9 F.3d 1104, 1111 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. §

10 416.902(a). Further, a district court “may not reverse an ALJ’s decision on 11 account of an error that is harmless.” Id. An error is harmless “where it is 12 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 18 the meaning of the Social Security Act. First, the claimant must be “unable to 19 engage in any substantial gainful activity by reason of any medically determinable

20 physical or mental impairment which can be expected to result in death or which 2 1 has lasted or can be expected to last for a continuous period of not less than twelve 2 months.” 42 U.S.C. § 1382c(a)(3)(A). Second, the claimant’s impairment must be

3 “of such severity that he is not only unable to do his previous work[,] but cannot, 4 considering his age, education, and work experience, engage in any other kind of 5 substantial gainful work which exists in the national economy.” 42 U.S.C. §

6 1382c(a)(3)(B). 7 The Commissioner has established a five-step sequential analysis to 8 determine whether a claimant satisfies the above criteria. See 20 C.F.R. § 9 416.920(a)(4)(i)-(v). At step one, the Commissioner considers the claimant’s work

10 activity. 20 C.F.R. § 416.920(a)(4)(i). If the claimant is engaged in “substantial 11 gainful activity,” the Commissioner must find that the claimant is not disabled. 20 12 C.F.R. § 416.920(b).

13 If the claimant is not engaged in substantial gainful activity, the analysis 14 proceeds to step two. At this step, the Commissioner considers the severity of the 15 claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from 16 “any impairment or combination of impairments which significantly limits [his or

17 her] physical or mental ability to do basic work activities,” the analysis proceeds to 18 step three. 20 C.F.R. § 416.920(c). If the claimant’s impairment does not satisfy 19 this severity threshold, however, the Commissioner must find that the claimant is

20 not disabled. Id. 2 1 At step three, the Commissioner compares the claimant’s impairment to 2 severe impairments recognized by the Commissioner to be so severe as to preclude

3 a person from engaging in substantial gainful activity. 20 C.F.R. § 4 416.920(a)(4)(iii). If the impairment is as severe or more severe than one of the 5 enumerated impairments, the Commissioner must find the claimant disabled and

6 award benefits. 20 C.F.R. § 416.920(d). 7 If the severity of the claimant’s impairment does not meet or exceed the 8 severity of the enumerated impairments, the Commissioner must pause to assess 9 the claimant’s “residual functional capacity.” Residual functional capacity (RFC),

10 defined generally as the claimant’s ability to perform physical and mental work 11 activities on a sustained basis despite his or her limitations, 20 C.F.R. § 12 416.945(a)(1), is relevant to both the fourth and fifth steps of the analysis.

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Heitschmidt v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heitschmidt-v-kijakazi-waed-2022.