Henning v. Kijakazi

CourtDistrict Court, E.D. Washington
DecidedJuly 19, 2023
Docket2:22-cv-00268
StatusUnknown

This text of Henning v. Kijakazi (Henning 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
Henning v. Kijakazi, (E.D. Wash. 2023).

Opinion

1 Jul 19, 2023 2 SEAN F. MCAVOY, CLERK 3 4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF WASHINGTON 8 9 10 TERESA H., No. 2:22-CV-00268-SAB 11 Plaintiff, 12 v. 13 COMMISSIONER OF SOCIAL ORDER AFFIRMING DECISION OF 14 SECURITY ADMINISTRATION, COMMISSIONER 15 Defendant. 16 17 Plaintiff brings this action seeking judicial review of the Commissioner of 18 Social Security’s final decision denying her application for social security benefits. 19 Plaintiff is represented by Chad L. Hatfield. The Commissioner is represented by 20 Edmund Darcher, Erin Highland, and Brian M. Donovan. Pending before the Court 21 are Plaintiff’s Opening Brief, ECF No. 14, the Commissioner’s Brief, ECF No. 16, 22 and Plaintiff’s Reply Brief, ECF No. 17. 23 After reviewing the administrative record, briefs filed by the parties, and 24 applicable case law, the Court is fully informed. For the reasons set forth below, 25 the Court affirms the Commissioner’s decision. 26 I. Jurisdiction 27 On August 25, 2017, Plaintiff filed an application for Title II disability 28 insurance benefits, with the onset date of July 12, 2017. Plaintiff’s application was 1 denied initially and on reconsideration. An ALJ found Plaintiff was not disabled 2 and Plaintiff appealed that decision to the Eastern District of Washington, which 3 remanded for additional proceedings. 4 On July 20, 2022, a hearing was held by telephone. Plaintiff participated and 5 was represented by Chad Hatfield. On September 9, 2022, the ALJ issued a ruling 6 again finding that Plaintiff was not disabled before July 14, 2020, but finding 7 Plaintiff became disabled on that date because her age category changed. Plaintiff 8 filed a timely appeal on November 8, 2022. ECF No. 1. The matter is before this 9 Court pursuant to 42 U.S.C. § 405(g). 10 II. Five-Step Sequential Evaluation Process 11 The Social Security Act defines disability as the “inability to engage in any 12 substantial gainful activity by reason of any medically determinable physical or 13 mental impairment which can be expected to result in death or which has lasted or 14 can be expected to last for a continuous period of not less than twelve months.” 42 15 U.S.C. § 423(d)(1)(A), 1382c(a)(3)(A). A claimant shall be determined to be under 16 a disability only if their impairments are of such severity that the claimant is not 17 only unable to do their previous work, but cannot, considering claimant’s age, 18 education, and work experiences, engage in any other substantial gainful work that 19 exists in the national economy. 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B). The 20 Commissioner has established a five-step sequential evaluation process to 21 determine whether a person is disabled in the statute. See 20 C.F.R. 22 § 404.1520(a)(4)(i)–(v), 416.920(a)(4)(i)–(v). 23 Step One: Is the claimant engaged in substantial gainful activities? Id. 24 § 404.1520(a)(4)(i), 416.920(a)(4)(i). Substantial gainful activity is work done for 25 pay and requires compensation above the statutory minimum. Keyes v. Sullivan, 26 894 F.2d 1053, 1057 (9th Cir. 1990). If the claimant is engaged in substantial 27 activity, benefits are denied. Id. § 404.1520(b), 416.920(b). If the claimant is not, 28 the ALJ proceeds to step two. 1 Step Two: Does the claimant have a medically-severe impairment or 2 combination of impairments? Id. § 404.1520(a)(4)(ii), 416.920(a)(4)(ii). A severe 3 impairment is one that lasted or must be expected to last for at least 12 months and 4 must be proven through objective medical evidence. Id. §§ 404.1509, 416.909. If 5 the claimant does not have a severe impairment or combination of impairments, the 6 disability claim is denied. Id. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the 7 impairment is severe, the evaluation proceeds to the third step. 8 Step Three: Does the claimant’s impairment meet or equal one of the listed 9 impairments acknowledged by the Commissioner to be so severe as to preclude 10 substantial gainful activity? Id. § 404.1520(a)(4)(iii), 416.920(a)(4)(iii). If the 11 impairment meets or equals one of the listed impairments, the claimant is 12 conclusively presumed to be disabled. Id. § 404.1520(d), 416.920(d). If the 13 impairment is not one conclusively presumed to be disabling, the evaluation 14 proceeds to the fourth step. 15 Before proceeding to the fourth step, the ALJ must first determine the 16 claimant’s residual functional capacity (RFC). An individual’s residual functional 17 capacity is their ability to do physical and mental work activities on a sustained 18 basis despite limitations from their impairments. Id. § 404.1545(a)(1), 19 416.945(a)(1). The RFC is relevant to both the fourth and fifth steps of the 20 analysis. 21 Step Four: Does the impairment prevent the claimant from performing work 22 they have performed in the past? Id. § 404.1520(a)(4)(iv), 416.920(a)(4)(iv). If the 23 claimant is able to perform their previous work, they are not disabled. Id. 24 § 404.1520(f), 416.920(f). If the claimant cannot perform this work, the evaluation 25 proceeds to the fifth and final step. 26 Step Five: Is the claimant able to perform other work in the national 27 economy in view of their age, education, and work experience? Id. 28 § 404.1520(a)(4)(v), 416.920(a)(4)(v). The initial burden of proof rests upon the 1 claimant to establish a prima facie case of entitlement to disability benefits. Tackett 2 v. Apfel, 108 F.3d 1094, 1098 (9th Cir. 1999). This burden is met once a claimant 3 establishes that a physical or mental impairment prevents him from engaging in her 4 previous occupation. Id. At step five, the burden shifts to the Commissioner to 5 show that the claimant can perform other substantial gainful activity. Id. 6 III. Standard of Review 7 The Commissioner’s determination will be set aside only when the ALJ’s 8 findings are based on legal error or are not supported by substantial evidence in the 9 record as a whole. Matney v. Sullivan, 981 F.2d 1016, 1018 (9th Cir. 1992) (citing 10 42 U.S.C. § 405(g)). Substantial evidence is “more than a mere scintilla,” 11 Richardson v. Perales, 402 U.S. 389, 401 (1971), but “less than a preponderance,” 12 Sorenson v. Weinberger, 514 F.2d 1112, 1119 n.10 (9th Cir. 1975). Substantial 13 evidence is “such relevant evidence as a reasonable mind might accept as adequate 14 to support a conclusion.” Richardson, 402 U.S. at 401. 15 A decision supported by substantial evidence will be set aside if the proper 16 legal standards were not applied in weighing the evidence and making the decision. 17 Brawner v. Secr’y of Health & Human Servs., 839 F.2d 432, 433 (9th Cir. 1988). 18 An ALJ is allowed “inconsequential” errors as long as they are immaterial to the 19 ultimate nondisability determination. Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 20 1050, 1055 (9th Cir. 2006). The court must uphold the ALJ’s denial of benefits if 21 the evidence is susceptible to more than one rational interpretation, one of which 22 supports the decision of the administrative law judge. Batson v. Barnhart, 359 F.3d 23 1190, 1193 (9th Cir. 2004).

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Richardson v. Perales
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Keyes v. Sullivan
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Henning v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henning-v-kijakazi-waed-2023.