Holder v. Dudek

CourtDistrict Court, D. Nevada
DecidedFebruary 26, 2025
Docket2:24-cv-00092
StatusUnknown

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

Bluebook
Holder v. Dudek, (D. Nev. 2025).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 6 VICTORIA H., Case No. 2:24-cv-00092-NJK

7 Plaintiff, Order 8 v. 9 LELAND C. DUDEK, 10 Defendant. 11 This case involves judicial review of administrative action by the Commissioner of Social 12 Security (“Commissioner”) denying Plaintiff’s application for disability and disability insurance 13 benefits pursuant to Title II of the Social Security Act. Currently before the Court are Plaintiff’s 14 motions to reverse and remand.1 Docket Nos. 20, 21. The Commissioner filed a responsive brief. 15 Docket No. 24. Plaintiff did not file a reply. See Docket. The parties consent to resolution of this 16 matter by the undersigned magistrate judge. Docket No. 1; see also Gen. Order. 2023-12. 17 I. STANDARDS 18 A. Judicial Standard of Review 19 The Court’s review of administrative decisions in social security disability benefits cases 20 is governed by 42 U.S.C. § 405(g). Akopyan v. Barnhart, 296 F.3d 852, 854 (9th Cir. 2002). 21 Section 405(g) provides that, “[a]ny individual, after any final decision of the Commissioner of 22 Social Security made after a hearing to which he was a party, irrespective of the amount in 23 controversy, may obtain a review of such decision by a civil action...brought in the district court 24 of the United States for the judicial district in which the plaintiff resides.” The Court may enter, 25 “upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing 26

27 1 For reasons unknown to the Court, Plaintiff filed two opening briefs. Docket Nos. 20, 21. As the briefs combined are below the page limit, see Local Rule 7-3, the Court will consider all 28 issues presented in both briefs. 1 the decision of the Commissioner of Social Security, with or without remanding the cause for a 2 rehearing.” Id. 3 The Commissioner’s findings of fact are deemed conclusive if supported by substantial 4 evidence. Id. To that end, the Court must uphold the Commissioner’s decision denying benefits 5 if the Commissioner applied the proper legal standard and there is substantial evidence in the 6 record as a whole to support the decision. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). 7 Substantial evidence is “more than a mere scintilla,” which equates to “such relevant evidence as 8 a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 9 U.S. 97, 139 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Id. In 10 determining whether the Commissioner’s findings are supported by substantial evidence, the Court 11 reviews the administrative record as a whole, weighing both the evidence that supports and the 12 evidence that detracts from the Commissioner’s conclusion. Reddick v. Chater, 157 F.3d 715, 720 13 (9th Cir. 1998). 14 Under the substantial evidence test, the Commissioner’s findings must be upheld if 15 supported by inferences reasonably drawn from the record. Batson v. Comm’r, Soc. Sec. Admin., 16 359 F.3d 1190, 1193 (9th Cir. 2004). When the evidence will support more than one rational 17 interpretation, the Court must defer to the Commissioner’s interpretation. Burch v. Barnhart, 400 18 F.3d 676, 679 (9th Cir. 2005). Consequently, the issue before this Court is not whether the 19 Commissioner could reasonably have reached a different conclusion, but whether the final decision 20 is supported by substantial evidence. 21 It is incumbent on the Administrative Law Judge (“ALJ”) to make specific findings so that 22 the Court does not speculate as to the basis of the findings when determining if the Commissioner’s 23 decision is supported by substantial evidence. The ALJ’s findings should be as comprehensive 24 and analytical as feasible and, where appropriate, should include a statement of subordinate factual 25 foundations on which the ultimate factual conclusions are based, so that a reviewing court may 26 know the basis for the decision. See, e.g., Gonzalez v. Sullivan, 914 F.2d 1197, 1200 (9th Cir. 27 1990). 28 1 B. Benefits Evaluation Process 2 The individual seeking disability benefits bears the initial burden of proving disability. 3 Roberts v. Shalala, 66 F.3d 179, 182 (9th Cir. 1995). To meet this burden, the individual must 4 demonstrate the “inability to engage in any substantial gainful activity by reason of any medically 5 determinable physical or mental impairment which can be expected...to last for a continuous period 6 of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). More specifically, the individual must 7 provide “specific medical evidence” in support of his claim for disability. See, e.g., 20 C.F.R. § 8 404.1514. If the individual establishes an inability to perform his prior work, then the burden 9 shifts to the Commissioner to show that the individual can perform other substantial gainful work 10 that exists in the national economy. Reddick, 157 F.3d at 721. 11 The ALJ follows a five-step sequential evaluation process in determining whether an 12 individual is disabled. Bowen v. Yuckert, 482 U.S. 137, 140 (1987) (citing 20 C.F.R. §§ 404.1520, 13 416.920). If at any step the ALJ determines that he can make a finding of disability or 14 nondisability, a determination will be made and no further evaluation is required. See Barnhart v. 15 Thomas, 540 U.S. 20, 24 (2003); see also 20 C.F.R. § 404.1520(a)(4). The first step requires the 16 ALJ to determine whether the individual is currently engaging in substantial gainful activity 17 (“SGA”). 20 C.F.R. § 404.1520(b). SGA is defined as work activity that is both substantial and 18 gainful; it involves doing significant physical or mental activities usually for pay or profit. 20 19 C.F.R. § 404.1572(a)-(b). If the individual is currently engaging in SGA, then a finding of not 20 disabled is made. If the individual is not engaging in SGA, then the analysis proceeds to the second 21 step. 22 The second step addresses whether the individual has a medically determinable impairment 23 that is severe or a combination of impairments that significantly limits him from performing basic 24 work activities. 20 C.F.R. § 404.1520(c). An impairment or combination of impairments is not 25 severe when medical and other evidence does not establish a significant limitation of an 26 individual's ability to work. See 20 C.F.R. §§ 404.1521, 404.1522.

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Holder v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holder-v-dudek-nvd-2025.