Hernandez v. Kijakazi

CourtDistrict Court, E.D. Washington
DecidedMay 11, 2021
Docket1:20-cv-03101
StatusUnknown

This text of Hernandez v. Kijakazi (Hernandez 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
Hernandez v. Kijakazi, (E.D. Wash. 2021).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 May 11, 2021

3 UNITED STATES DISTRICT COURT SEAN F. MCAVOY, CLERK EASTERN DISTRICT OF WASHINGTON 4 AIDE H., on behalf of J.H., a minor No. 1:20-cv-03101-SMJ 5 child, ORDER GRANTING PLAINTIFF’S 6 Plaintiff, MOTION FOR SUMMARY JUDGMENT AND DENYING 7 v. DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 8 ANDREW SAUL, Commissioner of Social Security, 9 Defendant. 10

11 Plaintiff Aide H., on behalf of minor child J.H., appeals the Administrative 12 Law Judge’s (ALJ) denial of J.H.’s application for Supplemental Security Income 13 (SSI) benefits. She alleges that the ALJ erred by (1) not obtaining a case evaluation 14 from an appropriate specialist based on the record in its entirety; (2) improperly 15 rejecting J.H.’s testimony; (3) improperly assessing the Listings and Domains; and 16 (4) improperly evaluation the opinion evidence. ECF No. 14 at 2. Defendant 17 disputes these contentions and asks the Court to affirm the ALJ’s determination. 18 ECF No. 15. 19 Before the Court, without oral argument, are the parties’ cross-motions for 20 summary judgment. ECF Nos. 14, 15. After reviewing the administrative record, 1 the parties’ briefs, and the relevant legal authority, the Court is fully informed. For 2 the reasons discussed below, the Court remands to the Social Security

3 Administration for additional proceedings. 4 BACKGROUND1 5 Plaintiff applied for SSI benefits for J.H. in January 2017, alleging an onset

6 date of January 1, 2014. AR 221.2 ALJ Caroline Siderius held a hearing in April 7 2019. AR 42. In May 2019, the ALJ determined that J.H. was not disabled and 8 denied the application. The Appeals Council denied Plaintiff’s request for review. 9 AR 1. Plaintiff then appealed to this Court. ECF No. 1.

10 DISABILITY DETERMINATION 11 A “disability” is defined as the “inability to engage in any substantial gainful 12 activity by reason of any medically determinable physical or mental impairment

13 which can be expected to result in death or which has lasted or can be expected to 14 last for a continuous period of not less than twelve months.” 42 U.S.C. 15 §§ 423(d)(1)(A), 1382c(a)(3)(A). In evaluating an application for benefits for an 16 individual under eighteen years of age, the decision-maker uses a three-step

17 sequential evaluation process to determine whether the claimant is disabled. 20 18 1 The facts, thoroughly stated in the record and the parties’ briefs, are only briefly 19 summarized here. See ECF Nos. 11, 14, 15 & 16. 2 References to the administrative record (AR), ECF No. 11, are to the provided 20 page numbers to avoid confusion. 1 C.F.R. § 416.924(a). 2 Step one assesses whether the claimant is engaged in substantial gainful

3 activities. If he or she is, benefits are denied. 20 C.F.R. § 416.924(b). If the claimant 4 is not, the decision-maker proceeds to step two. 5 Step two assesses whether the claimant has a severe medically determinable

6 impairment or combination of impairments. 20 C.F.R. §416.924(c). An impairment 7 or combination of impairments is not severe if it is a slight abnormality or 8 combination of abnormalities that causes no more than minimal functional 9 limitations. Id. If the claimant does not have a severe medically determinable

10 impairment or combination of impairments, the disability claim is denied. Id. If the 11 claimant does, the evaluation proceeds to the third step. 12 Step three compares the claimant’s impairment with a number of listed

13 impairments acknowledged by the Commissioner to be so severe as to preclude 14 substantial gainful activity. 20 C.F.R. § 416.924(d). If the impairment meets or is 15 medically or functionally equal to one of the listed impairments and has lasted or is 16 expected to last for a period of at least twelve consecutive months, the claimant is

17 presumed to be disabled. Id. The ALJ’s assessment of whether an impairment is 18 functionally equal to a listed impairment is based on six “domains,” or “broad areas 19 of functioning intended to capture all of what a child can or cannot do.” 20 C.F.R.

20 § 416.926a(b)(1). The six domains are: 1 (i) Acquiring and using information; 2 (ii) Attending and completing tasks;

3 (iii) Interacting and relating with others; 4 (iv) Moving about and manipulating objects; 5 (v) Caring for yourself; and

6 (vi) Health and physical well-being. 7 Id. A child’s impairment is functionally equal to a listed impairment if it results in 8 a “marked” limitation in two domains or an “extreme” limitation in any one. Id. at 9 § 416.929a(a). A limitation is “marked” if it interferes “seriously” with “[the

10 child’s] ability to independently initiate, sustain, or complete activities.” Id. at 11 § 416.926a(e)(2)(i). A limitation is “extreme” when it interferes “very seriously” 12 with “[the child’s] ability to independently initiate, sustain, or complete activities.”

13 Id. at § 416.926a(e)(3)(i). 14 ALJ FINDINGS 15 At step one, the ALJ found J.H. had not engaged in substantial gainful 16 activity since January 20, 2017, the application date. AR 24.

17 At step two, the ALJ found that J.H. had childhood-onset fluency disorder, 18 which was severe medically determinable impairment. AR 24. She also determined 19 that he had anxiety disorder and depression, which were nonsevere impairments.

20 AR 24–25. 1 At step three, the ALJ found that J.H. did not have an impairment or 2 combination of impairments that met or medically equaled the severity of a listed

3 impairment. AR 25. Nor did he have an impairment or combination of impairments 4 that functionally equaled the severity of the listings. Id. The ALJ found that J.H. did 5 not have marked or extreme limitations in any of the six domains. AR 29–35.

6 STANDARD OF REVIEW 7 Reviewing courts must uphold an ALJ’s disability determination if it applied 8 the proper legal standards and supported its decision with substantial evidence in 9 the record. Molina v. Astrue, 674 F.3d 1104, 1110 (9th Cir. 2012), superseded by

10 regulation on other grounds. “Substantial evidence ‘means such relevant evidence 11 as a reasonable mind might accept as adequate to support a conclusion.’” Id. 12 (quoting Valentine v. Comm’r Soc. Sec. Admin., 574 F.3d 685, 690 (9th Cir. 2009)).

13 “[W]hatever the meaning of ‘substantial’ in other contexts, the threshold for such 14 evidentiary sufficiency is not high.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 15 (2019). The ALJ must base its determination on “more than a mere scintilla” of 16 evidence, id. at 1154, but need not support its decision by a preponderance of the

17 evidence. Molina, 674 F.3d at 1111. If the evidence supports more than one rational 18 interpretation, and the ALJ has supported its decision with inferences drawn 19 reasonably from the record, the Court must uphold its decision. Id.; Allen v. Heckler,

20 749 F.2d 577, 579 (9th Cir. 1984). 1 Moreover, the Court will not reverse an ALJ’s decision if it committed 2 harmless error. Molina, 674 F.3d at 1111. The burden to show harmful error lies

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Bluebook (online)
Hernandez v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-kijakazi-waed-2021.