Hernandez v. O'Malley

CourtDistrict Court, E.D. Washington
DecidedSeptember 12, 2023
Docket1:23-cv-03048
StatusUnknown

This text of Hernandez v. O'Malley (Hernandez v. O'Malley) 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. O'Malley, (E.D. Wash. 2023).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 EFRAHIN H., NO. 1:23-CV-3048-TOR 8 Plaintiff, ORDER AFFIRMING 9 v. COMMISSIONER’S DENIAL OF BENEFITS UNDER TITLES II & XVI 10 KILOLO KIJAKAZI, Acting OF THE SOCIAL SECURITY ACT Commissioner of Social Security, 11 Defendant. 12

13 BEFORE THE COURT is Plaintiff’s motion for judicial review of 14 Defendant’s denial of his applications for disability insurance benefits and 15 supplemental security income (“SSI”) benefits (ECF No. 9). The matter was 16 submitted for consideration without oral argument. The Court has reviewed the 17 administrative record and the completed briefing and is fully informed. For the 18 reasons discussed below, the Commissioner’s denial of Plaintiff’s application for 19 benefits under Title II and Title XVI of the Social Security Act is AFFIRMED. 20 // 1 JURISDICTION 2 The Court has jurisdiction under 42 U.S.C. §§ 405(g), 1383(c)(3).

3 STANDARD OF REVIEW 4 A district court’s review of a final decision of the Commissioner of Social 5 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is

6 limited: the Commissioner’s decision will be disturbed “only if it is not supported 7 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 8 1158-59 (9th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence” means 9 relevant evidence that “a reasonable mind might accept as adequate to support a

10 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, 11 substantial evidence equates to “more than a mere scintilla[,] but less than a 12 preponderance.” Id. (quotation and citation omitted). In determining whether this

13 standard has been satisfied, a reviewing court must consider the entire record as a 14 whole rather than searching for supporting evidence in isolation. Id. 15 In reviewing a denial of benefits, a district court may not substitute its 16 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152,

17 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 18 rational interpretation, [the court] must uphold the ALJ’s findings if they are 19 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674

20 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an 1 ALJ’s decision on account of an error that is harmless.” Id. An error is harmless 2 “where it is inconsequential to the [ALJ’s] ultimate nondisability determination.”

3 Id. at 1115 (quotation and citation omitted). The party appealing the ALJ’s 4 decision generally bears the burden of establishing that it was harmed. Shinseki v. 5 Sanders, 556 U.S. 396, 409-10 (2009).

6 FIVE-STEP SEQUENTIAL EVALUATION PROCESS 7 A claimant must satisfy two conditions to be considered “disabled” within 8 the meaning of the Social Security Act. First, the claimant must be unable “to 9 engage in any substantial gainful activity by reason of any medically determinable

10 physical or mental impairment which can be expected to result in death or which 11 has lasted or can be expected to last for a continuous period of not less than 12 12 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). Second, the claimant’s

13 impairment must be “of such severity that he is not only unable to do his previous 14 work[,] but cannot, considering his age, education, and work experience, engage in 15 any other kind of substantial gainful work which exists in the national economy.” 16 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B).

17 The Commissioner has established a five-step sequential analysis to 18 determine whether a claimant satisfies the above criteria. See 20 C.F.R. §§ 19 404.1520(a)(4)(i)-(v), 416.920(a)(4)(i)-(v). At step one, the Commissioner

20 considers the claimant’s work activity. 20 C.F.R. §§ 404.1520(a)(4)(i), 1 416.920(a)(4)(i). If the claimant is engaged in “substantial gainful activity,” the 2 Commissioner must find that the claimant is not disabled. 20 C.F.R. §§

3 404.1520(b), 416.920(b). Substantial work activity is “activity that involves doing 4 significant physical or mental activities,” even if performed on a part-time basis. 5 20 C.F.R. § 404.1572(a). “Gainful work activity” is work performed “for pay or

6 profit,” or “the kind of work usually done for pay or profit, whether or not a profit 7 is realized.” 20 C.F.R. § 404.1572(b). 8 If the claimant is not engaged in substantial gainful activity, the analysis 9 proceeds to step two. At step two, the Commissioner considers the severity of the

10 claimant’s impairment. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the 11 claimant suffers from “any impairment or combination of impairments which 12 significantly limits [his] physical or mental ability to do basic work activities,” the

13 analysis proceeds to step three. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the 14 claimant’s impairment does not satisfy this severity threshold, the Commissioner 15 must find that the claimant is not disabled. Id. 16 At step three, the Commissioner compares the claimant’s impairment to

17 several impairments recognized to be so severe as to preclude a person from 18 engaging in substantial gainful activity. 20 C.F.R. §§ 404.1520(a)(4)(iii), 19 416.920(a)(4)(iii). If the impairment is as severe or more severe than one of the

20 enumerated impairments, the Commissioner must find the claimant disabled and 1 award benefits. 20 C.F.R. §§ 404.1520(d), 416.920(d). 2 If the severity of the claimant’s impairment does meet or exceed the severity

3 of the enumerated impairments, the Commissioner must pause to assess the 4 claimant’s “residual functional capacity” (“RFC”) before awarding benefits. RFC 5 is generally defined as the claimant’s ability to perform physical and mental work

6 activities on a sustained basis despite his limitations (20 C.F.R. §§ 404.1545(a)(1), 7 416.945(a)(1)), and is relevant to both the fourth and fifth steps of the analysis. 8 At step four, the Commissioner considers whether, in view of the RFC, the 9 claimant is capable of performing relevant work that he has performed in the past.

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Hernandez v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-omalley-waed-2023.