Hernandez v. Commissioner of the Social Security Administration

CourtDistrict Court, S.D. California
DecidedJanuary 24, 2025
Docket3:23-cv-02087
StatusUnknown

This text of Hernandez v. Commissioner of the Social Security Administration (Hernandez v. Commissioner of the Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, S.D. California 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 the Social Security Administration, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 SOUTHERN DISTRICT OF CALIFORNIA 8 9 MARIA H.,1 Case No.: 23-cv-02087-GPC-MMP

10 Plaintiff, REPORT AND 11 v. RECOMMENDATION REGARDING PLAINTIFF’S MERITS BRIEF 12 COMMISSIONER OF THE SOCIAL

SECURITY ADMINISTRATION, 13 [ECF No. 16]

14 Defendant. 15 16 Plaintiff Maria H. (“Plaintiff”) appeals the final decision of the Commissioner of 17 Social Security (“the Commissioner”) denying her application for disability insurance and 18 supplemental security income benefits under Titles II and XVI of the Social Security Act. 19 [ECF No. 5.] 20 This matter comes before the Court for a Report and Recommendation (“R&R”) on 21 Plaintiff’s Merits Brief. [ECF No. 16.] Defendant Commissioner filed a Responsive Brief, 22 and Plaintiff filed a Reply Brief. [ECF Nos. 17, 18.] After a thorough review of the parties’ 23 submissions, the administrative record, and applicable law, the Court RECOMMENDS 24 the District Judge REVERSE the Commissioner’s denial and REMAND the matter for 25 further proceedings consistent with this opinion. 26

27 1 In accordance with Civil Local Rule 7.1(e)(6)(b), the Court refers to all non-government 28 1 I. BACKGROUND 2 A. Procedural History 3 Plaintiff first applied for disability insurance and supplemental security income 4 benefits on January 17, 2018, claiming disability beginning July 15, 2017. Administrative 5 Record (“AR”) 69. These claims were denied on May 14, 2018, and upon reconsideration 6 on September 6, 2018. See AR 69–80, 105. The Administrative Law Judge (“ALJ”) held a 7 telephonic hearing on these claims on August 6, 2020, and issued an unfavorable decision 8 on August 21, 2020. AR 69–80, 105. Plaintiff appealed the ALJ’s decision to this Court in 9 case no. 20-cv-2532-RBB. AR 96. 10 While the January 2018 case’s appeal was pending, Plaintiff filed additional 11 applications for disability insurance and supplemental security income benefits on 12 September 24, 2021. AR 172, 263–66, 267–72. Plaintiff’s alleged impairments include: 13 “Severe depression, Anxiety, PTSD; Diabetes; High blood pressure; Fibromyalgia; 14 Arthritis back, neck, knees, ankles, hips; Tendinitis and carpal tunnel bilateral hands; [and] 15 Chronic pain in [her] whole body.” AR 102. The alleged date of onset was July 17, 2017— 16 two days after Plaintiff’s first claim.2 AR 102. The claims were denied by initial 17 determination on December 16, 2021, and upon reconsideration on September 6, 2022. AR 18 101–28, 129–68, 204. Plaintiff requested a hearing and received a telephonic hearing on 19 April 21, 2023. AR 172, 230. During the hearing, Plaintiff amended the alleged onset date 20 to September 1, 2020. AR 26, 173. The ALJ issued an unfavorable decision on June 23, 21 2023. AR 183. 22 Plaintiff requested Appeals Council review, which was denied on September 11, 23 2023. AR 1, 6–16. The ALJ’s decision then became the final decision of the Commissioner 24 of Social Security. 25

26 27 2 The ALJ determined Plaintiff rebutted the presumption of continuing nondisability under SSAR 97-4(9) because the second application alleged impairments not previously 28 1 B. General Background 2 Plaintiff was a fifty-five-year-old woman at the original alleged date of onset (July 3 17, 2017). AR 101. Her most recent employment was as a caregiver eight (8) hours per 4 week, and before that she did semi-skilled clerical work at a hospital and motel. AR 18. 5 Her highest level of education is a general associate’s degree. AR 17. 6 II. SUMMARY OF THE ALJ’S FINDINGS 7 A. The Five-Step Evaluation Process 8 The ALJ follows a five-step sequential evaluation process in assessing whether a 9 claimant is disabled. 20 C.F.R. §§ 404.1520, 416.920; Tackett v. Apfel, 180 F.3d 1094, 10 1098–99 (9th Cir. 1999). In the first step, the Commissioner must determine whether the 11 claimant is currently engaged in substantial gainful activity; if so, the claimant is not 12 disabled, and the claim is denied. 20 C.F.R. § 404.1520(a)(4)(i) and (b); see also 20 C.F.R. 13 § 416.920(a)(4)(i) and (b). 14 If the claimant is not currently engaged in substantial gainful activity, the second 15 step requires the ALJ to determine whether the claimant has a “severe” impairment or 16 combination of impairments significantly limiting her ability to do basic work activities 17 and which has lasted or is expected to last for a continuous period of at least twelve months; 18 if not, the claimant is not disabled, and the claim is denied. 20 C.F.R. §§ 404.1520(a)(4)(ii) 19 and (c), 404.1509 (setting forth the twelve-month duration requirement); see also 20 C.F.R. 20 §§ 416.920(a)(4)(ii) and (c), 416.909. 21 If the claimant has a “severe” impairment or combination of impairments, the third 22 step requires the ALJ to determine whether the impairment or combination of impairments 23 meets or equals an impairment in the Listing of Impairments (“Listing”) set forth at 20 24 C.F.R. § 404, subpart P, appendix 1; if so, disability is conclusively presumed, and benefits 25 are awarded. 20 C.F.R. § 404.1520(a)(4)(iii) and (d); see also 20 C.F.R. § 416.920(a)(4)(iii) 26 and (d). 27 If the claimant’s impairment or combination of impairments does not meet or equal 28 an impairment in the Listing, the ALJ proceeds to the fourth step of the disability evaluation 1 process. 20 C.F.R. §§ 404.1520(e), 416.920(e). The fourth step requires the ALJ to 2 determine whether the claimant has sufficient residual functional capacity (“RFC”) to 3 perform her past work. 20 C.F.R. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). If the ALJ 4 determines a claimant has sufficient RFC to perform past relevant work, the claimant is not 5 disabled, and the claim is denied. 20 C.F.R. § 404.1520(a)(4)(iv) and (f)–(g); see also § 6 416.920(a)(4)(iv) and (f)–(g). 7 The RFC is “an assessment of an individual’s ability to do sustained work-related 8 physical and mental activities in a work setting on a regular and continuing basis.” Titles 9 II & XVI: Assessing Residual Functional Capacity in Initial Claims, SSR 96-8p, 1996 WL 10 374184, at *1 (July 2, 1996). It reflects the most a claimant can do despite her limitations. 11 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1); SSR 96-8p, 1996 WL 374184, at *1 (“RFC is 12 not the least an individual can do despite his or her limitations or restrictions, but the 13 most.”). An RFC assessment must include an individual’s functional limitations or 14 restrictions as a result of all her impairments—even those that are not severe—and must 15 assess her “work-related abilities on a function-by-function basis.” SSR 96-8p, 1996 WL 16 374184, at *1; see 20 C.F.R.

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Hernandez v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-commissioner-of-the-social-security-administration-casd-2025.