Higgins v. Commissioner of Social Security

CourtDistrict Court, D. Idaho
DecidedJune 11, 2025
Docket2:24-cv-00252
StatusUnknown

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

Bluebook
Higgins v. Commissioner of Social Security, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO ALYCE L. H.,1

Plaintiff, Case No. 1:24-cv-00252-DKG v. MEMORANDUM DECISION AND ORDER COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION,

Defendant.

INTRODUCTION Plaintiff filed a Complaint for judicial review of the Commissioner’s denial of her application for disability and disability insurance benefits. (Dkt. 1). Having reviewed the Complaint, the parties’ memoranda, and the administrative record (AR), the Court will affirm the decision of the Commissioner for the reasons set forth below.

1 Plaintiff’s name is partially redacted in compliance with Federal Rule of Civil Procedure 5.2(c)(2)(B) and the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States. BACKGROUND On July 19, 2021, Plaintiff protectively filed a Title II application for a period of disability and disability insurance benefits, alleging disability beginning on September 7,

2017. (AR 17). Her date last insured for disability benefits was December 31, 2019, meaning the period under review was September 7, 2017, through December 31, 2019. (AR 19). Plaintiff’s application was denied initially and on reconsideration. A hearing was conducted on June 21, 2023, before Administrative Law Judge (ALJ) Lori L. Freund. (AR 17).2

After considering testimony from Plaintiff, the ALJ issued a written decision on September 15, 2023, finding Plaintiff not disabled. (AR 17-22). The Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision final. See 42 U.S.C. § 405(h). Plaintiff timely filed this action seeking judicial review of the ALJ’s decision. (Dkt. 1). The Court has jurisdiction pursuant to 42 U.S.C. § 405(g).

Plaintiff was fifty-seven years of age on the alleged onset date, which is defined as an individual of advanced age. (Dkt. 15 at 4); 20 C.F.R. § 404.1563. Plaintiff has at least a high school education with past relevant work experience as a personal care assistant and caregiver. Id. Plaintiff claims disability due to physical and mental impairments including chronic pulmonary obstructive disease (“COPD”), tobacco dependence, and a

history of hypertension. (AR 19).

2 The hearing was conducted telephonically, per Plaintiff’s agreement prior to the hearing. (AR 17, 124). THE ALJ’S DECISION Disability is the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to

result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). The ALJ engages in a five-step sequential inquiry to determine whether a claimant is disabled within the meaning of the Act. 20 C.F.R. § 404.1520; Lounsburry v. Barnhart, 468 F.3d 1111, 1114 (9th Cir. 2006) (discussing Tackett v. Apfel, 180 F.3d 1094, 1098-99 (9th Cir. 1999)).

Here, at step one, the ALJ found Plaintiff last met the insured status requirements of the Social Security Act on December 31, 2019. (AR 19). The ALJ determined that Plaintiff had not engaged in substantial gainful activity during the period from her alleged onset date of September 7, 2017, through her date last insured of December 31, 2019. Id. At step two, the ALJ determined Plaintiff suffers from the following medically

determinable impairments: COPD, tobacco dependence, and history of hypertension. Id. However, the ALJ found that through the date last insured, Plaintiff did not have an impairment or combination of impairments that significantly limited her ability to perform basic work-related activities for 12 consecutive months, and therefore determined Plaintiff’s COPD, tobacco dependence, and history of hypertension to be

non-severe. Id. As such, the ALJ at step two found Plaintiff had not been under a disability, as defined in the Social Security Act, at any time from September 7, 2017, the alleged onset date, through December 31, 2019, the date last insured. (AR 22). STANDARD OF REVIEW

The Court will uphold an ALJ’s decision unless: (1) the decision is based on legal error, or (2) the decision is not supported by substantial evidence. Revels v. Berryhill, 874 F.3d 648, 654 (9th Cir. 2017). Substantial evidence is “‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). This requires “more than a mere scintilla” of evidence. Id. The Court must consider the administrative record as a whole. Garrison v. Colvin,

759 F.3d 995, 1009 (9th Cir. 2014). It must weigh both the evidence that supports, and the evidence that does not support, the ALJ’s conclusion. Id. If the ALJ’s decision is based on a rational interpretation of conflicting evidence, the Court will uphold the ALJ’s finding. Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155, 1165 (9th Cir. 2008). It is unnecessary for the ALJ to “discuss all evidence

presented.” Vincent on Behalf of Vincent v. Heckler, 739 F.2d 1393, 1394-95 (9th Cir. 1984) (citation omitted) (emphasis in original). The ALJ must, however, explain why “significant probative evidence has been rejected.” Id. DISCUSSION The sole issue raised on appeal is whether the ALJ erred by finding Plaintiff’s

COPD to be a non-severe impairment and ending the sequential inquiry at step two. (Dkt. 15 at 9). In order to obtain disability insurance benefits, Plaintiff must establish disability before the date last insured. See 42 U.S.C. § 423(c); 20 C.F.R. § 404.1520. The burden of proof on this issue is on the plaintiff. See Morgan v. Sullivan, 945 F.2d 1079, 1080-81 (9th Cir. 1991). In this case, Plaintiff’s date last insured is December 31, 2019, meaning Plaintiff must establish disability before that date. (AR 19). To best address Plaintiff’s argument, the Court shall briefly review the applicable rules and the ALJ’s findings at

step two. At step two of the sequential evaluation process, the ALJ must determine whether the claimant suffers from a “severe” impairment or combination of impairments. Smolen v. Chater, 80 F.3d 1273, 1290-91 (9th Cir. 1996).

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Smolen v. Chater
80 F.3d 1273 (Ninth Circuit, 1996)

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