Henderson v. Saul

CourtDistrict Court, D. Nevada
DecidedFebruary 18, 2020
Docket2:19-cv-00028
StatusUnknown

This text of Henderson v. Saul (Henderson v. Saul) 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
Henderson v. Saul, (D. Nev. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 RICHARD W. HENDERSON, Case No.: 2:19-cv-00028-NJK

12 Plaintiff(s), ORDER 13 v. 14 ANDREW SAUL, 15 Defendant(s). 16 This case involves judicial review of administrative action by the Commissioner of Social 17 Security (“Commissioner”) denying Plaintiff’s application for disability insurance benefits 18 pursuant to Title XVI of the Social Security Act. Currently before the Court is Plaintiff’s Motion 19 for Reversal and/or Remand. Docket No. 21. The Commissioner filed a response in opposition 20 and a cross-motion to affirm. Docket Nos. 22-23. Plaintiff filed a reply. Docket No. 24. The 21 parties consented to resolution of this matter by the undersigned magistrate judge. Docket No. 25. 22 I. STANDARDS 23 A. Disability Evaluation Process 24 The standard for determining disability is whether a social security claimant has an 25 “inability to engage in any substantial gainful activity by reason of any medically determinable 26 physical or mental impairment which can be expected . . . to last for a continuous period of not 27 less than 12 months.” 42 U.S.C. § 423(d)(1)(A); see also 42 U.S.C. § 1382c(3)(A). That 28 determination is made by following a five-step sequential evaluation process. Bowen v. Yuckert, 1 482 U.S. 137, 140 (1987) (citing 20 C.F.R. §§ 404.1520, 416.920). The first step addresses 2 whether the claimant is currently engaging in substantial gainful activity. 20 C.F.R. §§ 3 404.1520(b), 416.920(b).1 The second step addresses whether the claimant has a medically 4 determinable impairment that is severe or a combination of impairments that significantly limits 5 basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). The third step addresses whether the 6 claimant’s impairments or combination of impairments meet or medically equal the criteria of an 7 impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. 20 C.F.R. §§ 404.1520(d), 8 404.1525, 404.1526, 416.920(d), 416.925, 416.926. There is then a determination of the 9 claimant’s residual functional capacity, which assesses the claimant’s ability to do physical and 10 mental work-related activities. 20 C.F.R. §§ 404.1520(e), 416.920(e). The fourth step addresses 11 whether the claimant has the residual functional capacity to perform past relevant work. 20 C.F.R. 12 §§ 404.1520(f), 416.920(f). The fifth step addresses whether the claimant is able to do other work 13 considering the residual functional capacity, age, education, and work experience. 20 C.F.R. §§ 14 404.1520(g), 416.920(g). 15 B. Judicial Review 16 After exhausting the administrative process, a claimant may seek judicial review of a 17 decision denying social security benefits. 42 U.S.C. § 405(g). The Court must uphold a decision 18 denying benefits if the proper legal standard was applied and there is substantial evidence in the 19 record as a whole to support the decision. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). 20 Substantial evidence is “more than a mere scintilla,” which equates to “such relevant evidence as 21 a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, ___ 22 U.S. ____, 139 S.Ct. 1148, 1154 (2019). “[T]he threshold for such evidentiary sufficiency is not 23 high.” Id. 24 25 26 27 1 The five-step process is largely the same for both Title II and Title XVI claims. For a 28 Title II claim, however, a claimant must also meet insurance requirements. 20 C.F.R. § 404.130. 1 II. BACKGROUND 2 A. Procedural History 3 On February 9, 2015, Plaintiff filed an application for supplemental security income with 4 an alleged disability onset date of October 1, 2007. See, e.g., Administrative Record (“A.R.”) 519- 5 26. On August 24, 2015, Plaintiff’s claim was denied initially. A.R. 444-48. On January 21, 6 2016, Plaintiff’s claim was denied on reconsideration. A.R. 456-61. On February 5, 2016, Plaintiff 7 filed a request for a hearing before an administrative law judge. A.R. 462-64. On 8 April 6, 2017, Plaintiff, Plaintiff’s representative, and a vocational expert appeared for a hearing 9 before ALJ Cynthia Hoover. See A.R. 393-416. On November 13, 2017, the ALJ issued an 10 unfavorable decision finding that Plaintiff had not been under a disability since the date the 11 application was filed. A.R. 39-56. On November 9, 2018, the ALJ’s decision became the final 12 decision of the Commissioner when the Appeals Council denied Plaintiff’s request for review. 13 A.R. 1-7. 14 On January 3, 2019, Plaintiff commenced this action for judicial review. Docket No. 1. 15 B. The Decision Below 16 The ALJ’s decision followed the five-step sequential evaluation process set forth in 20 17 C.F.R. § 416.920. A.R. 42-51. At step one, the ALJ found that Plaintiff has not engaged in 18 substantial gainful activity since the application date. A.R. 44. At step two, the ALJ found that 19 Plaintiff has the following severe impairments: hearing loss, loss of speech, diabetes mellitus, skin 20 cancer, history of fracture of the lower extremity, and degenerative disc disease. A.R. 44-47. At 21 step three, the ALJ found that Plaintiff does not have an impairment or combination of impairments 22 that meets or medically equals the severity of one of the listed impairments in 20 C.F.R. Part 404, 23 Subpart P, Appendix 1. A.R. 47. The ALJ found that Plaintiff has the residual functional capacity 24 to perform the full range of medium work as defined by 20 C.F.R. § 416.967(c). A.R. 47-49. At 25 step four, the ALJ found Plaintiff capable of performing past relevant work as a truck driver. A.R. 26 49-50. The ALJ included an alternative finding that Plaintiff could also perform other jobs existing 27 in significant numbers in the national economy. A.R. 50-51. 28 1 Based on all of these findings, the ALJ found Plaintiff not disabled since the date of the 2 application. A.R. 51. 3 III. ANALYSIS 4 Plaintiff raises a single issue on appeal, asserting that the ALJ erred in discounting his 5 testimony of disabling limitations. Credibility and similar determinations are quintessential 6 functions of the judge taking witness testimony, so reviewing courts generally give deference to 7 such assessments. See, e.g., Icicle Seafoods, Inc. v.

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Henderson v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henderson-v-saul-nvd-2020.