Hernandez v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedJune 24, 2022
Docket2:20-cv-02070
StatusUnknown

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

Bluebook
Hernandez v. Commissioner of Social Security Administration, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Karina Hernandez, No. CV-20-02070-PHX-JAT

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court is Plaintiff Karina Hernandez’s appeal from the 16 Commissioner of the Social Security Administration’s (“SSA”) denial of social security 17 supplemental income. (Doc. 19). The appeal is fully briefed (Doc. 19, Doc. 25, Doc. 26), 18 and the Court now rules. 19 I. BACKGROUND 20 The issues presented in this appeal are whether Plaintiff was deprived of a valid 21 adjudicatory process, whether substantial evidence supports the Administrative Law 22 Judge’s (“ALJ”) determination that Plaintiff was not disabled from August 22, 2017, to 23 May 26, 2020, and whether the ALJ committed legal error in her analysis. (Doc. 19 at 1). 24 a. Factual Overview 25 Plaintiff was 40 years old at the date of her application. (Doc. 16-3 at 39). She has 26 an 11th grade education and no past relevant work experience. (Id.). Plaintiff filed her 27 social security supplemental income claim on August 22, 2017, alleging disabilities 28 beginning on January 1, 2004, including degenerative disc disease of the cervical and 1 lumbar spine, clinical obesity, depression, and anxiety. (Id. at 31). An ALJ denied 2 Plaintiff’s claim on May 26, 2020. (Id. at 40). The SSA Appeals Council denied a request 3 for review of that decision and adopted the ALJ’s decision as the agency’s final decision. 4 (Id. at 2). 5 b. The SSA’s Five-Step Evaluation Process 6 To qualify for social security benefits, a claimant must show she “is under a 7 disability.” 42 U.S.C. § 423(a)(1)(E). A claimant is disabled if she suffers from a medically 8 determinable physical or mental impairment that prevents her from engaging “in any 9 substantial gainful activity.” Id. § 423(d)(1)–(2). The SSA has created a five-step process 10 for an ALJ to determine whether the claimant is disabled. See 20 C.F.R. § 404.1520(a)(1). 11 Each step is potentially dispositive. See id. § 404.1520(a)(4). 12 At the first step, the ALJ determines whether the claimant is “doing substantial 13 gainful activity.” Id. § 404.1520(a)(4)(i). If so, the claimant is not disabled. Id. Substantial 14 gainful activity is work activity that is both “substantial,” involving “significant physical 15 or mental activities,” and “gainful,” done “for pay or profit.” Id. § 404.1572(a)–(b). 16 At the second step, the ALJ considers the medical severity of the claimant’s 17 impairments. Id. § 404.1520(a)(4)(ii). If the claimant does not have “a severe medically 18 determinable physical or mental impairment,” the claimant is not disabled. Id. A “severe 19 impairment” is one which “significantly limits [the claimant’s] physical or mental ability 20 to do basic work activities.” Id. § 404.1520(c). Basic work activities are “the abilities and 21 aptitudes necessary to do most jobs.” Id. § 404.1522(b). 22 At the third step, the ALJ determines whether the claimant’s impairment or 23 combination of impairments “meets or equals” an impairment listed in Appendix 1 to 24 Subpart P of 20 C.F.R. Part 404. Id. § 404.1520(a)(4)(iii). If so, the claimant is disabled. 25 Id. If not, before proceeding to step four, the ALJ must assess the claimant’s “residual 26 functional capacity” (“RFC”). Id. § 404.1520(a)(4). The RFC represents the most a 27 claimant “can still do despite [her] limitations.” Id. § 404.1545(a)(1). In assessing the 28 claimant’s RFC, the ALJ will consider the claimant’s “impairment(s), and any related 1 symptoms, such as pain, [that] may cause physical and mental limitations that affect what 2 [the claimant] can do in a work setting.” Id. 3 At the fourth step, the ALJ uses the RFC to determine whether the claimant can still 4 perform her “past relevant work.” Id. § 404.1520(a)(4)(iv). The ALJ compares the 5 claimant’s RFC with the physical and mental demands of the claimant’s past relevant work. 6 Id. § 404.1520(f). If the claimant can still perform her past relevant work, the ALJ will find 7 that the claimant is not disabled. Id. § 404.1520(a)(4)(iv). 8 At the fifth and final step, the ALJ determines whether—considering the claimant’s 9 RFC, age, education, and work experience—she “can make an adjustment to other work.” 10 Id. § 404.1520(a)(4)(v). If the ALJ finds that the claimant can make an adjustment to other 11 work, then the claimant is not disabled. Id. If the ALJ finds that the claimant cannot make 12 an adjustment to other work, then the claimant is disabled. Id. 13 c. The ALJ’s Application of the Factors 14 Here, at the first step, the ALJ concluded that Plaintiff had not engaged in substantial 15 gainful activity since the alleged onset date of her disability. (Doc. 16-3 at 30). 16 At the second step, the ALJ determined that Plaintiff’s degenerative disc disease of 17 the cervical and lumbar spine, clinical obesity, depression, and anxiety constituted severe 18 impairments under 20 C.F.R. 404.1520(c). (Id. at 31). The ALJ also determined that the 19 rest of Plaintiff’s alleged impairments were non-severe. (Id. at 31–32). 20 At the third step, the ALJ determined that Plaintiff’s impairments did not meet the 21 severity of one of the impairments listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Id. 22 at 32). After evaluating Plaintiff’s RFC, the ALJ concluded that Plaintiff could perform 23 light work as defined in 20 C.F.R. 404.1567(b) “except with no more than frequent 24 fingering, handling, and reaching overhead with the right upper extremity; occasional 25 climbing of ramps and stairs, stooping, kneeling, crouching or crawling; no climbing 26 ladders, ropes, and scaffolding; and she must avoid unprotected heights and hazardous 27 machinery.” (Id. at 34). The ALJ also found that Plaintiff is “limited to understanding, 28 remembering, and carrying out simple tasks and job instructions; routine changes in the 1 workplace; and no more than occasional interaction with supervisors, coworkers, and the 2 general public.” (Id.) 3 At the fourth step, the ALJ concluded that Plaintiff has no past relevant work. (Id. 4 at 39). 5 At the fifth step and final step, the ALJ concluded that given Plaintiff’s age, 6 education, work experience, and RFC, a significant number of jobs existed in the national 7 economy that she could have performed. (Id.) Accordingly, the ALJ determined that 8 Plaintiff was not disabled. (Id. at 40). 9 II. LEGAL STANDARD 10 This Court may not overturn the ALJ’s denial of disability benefits absent legal error 11 or a lack of substantial evidence. Luther v. Berryhill, 891 F.3d 872, 875 (9th Cir. 2018). 12 “Substantial evidence means … such relevant evidence as a reasonable mind might accept 13 as adequate to support a conclusion.” Revels v. Berryhill, 874 F.3d 648, 654 (9th Cir. 2017) 14 (quoting Desrosiers v. Sec’y of Health & Human Servs., 846 F.2d 573, 576 (9th Cir. 1988)).

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Bluebook (online)
Hernandez v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-commissioner-of-social-security-administration-azd-2022.