Houck v. Bisignano

CourtDistrict Court, E.D. Washington
DecidedJune 6, 2025
Docket4:24-cv-05154
StatusUnknown

This text of Houck v. Bisignano (Houck v. Bisignano) 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
Houck v. Bisignano, (E.D. Wash. 2025).

Opinion

1 FILED IN THE 2 EASTER U N . S D . I S D T I R S I T C R T I C O T F C W O A U S R H T I NGTON Jun 06, 2025 3

SEAN F. MCAVOY, CLERK 4 UNITED STATES DISTRICT COURT 5 EASTERN DISTRICT OF WASHINGTON

6 ARIEL H.,1 NO: 4:24-CV-05154-RLP 7 Plaintiff,

8 v. ORDER AFFIRMING THE COMMISSIONER’S DECISION 9 FRANK BISIGNANO COMMISSIONER OF SOCIAL 10 SECURITY,2

11 Defendant. 12 BEFORE THE COURT is an appeal from an Administrative Law Judge 13 (ALJ) final decision denying disability income benefits under Title II and 14 supplemental security income under Title XVI of the Social Security Act. ECF No. 15 12. The Court considered the matter without oral argument. For the reasons 16 discussed below, the Court concludes the ALJ did not commit harmful legal error in 17

18 1 Plaintiff’s first name and last initial are used to protect his privacy. 19 2 Frank Bisignano became the Commissioner of Social Security on May 7, 20 2025. Pursuant to Rule 25(d) of the Rules of Civil Procedure, Frank Bisignano is 21 substituted for Michelle King as the Defendant in this suit. 1 evaluating the lay witness testimony, Mr. H.’s symptom testimony, or the medical 2 evidence. Therefore, Mr. H.’s brief, ECF No. 12, is denied and the Commissioner’s 3 brief, ECF No. 14, is granted. 4 BACKGROUND

5 Mr. H. was 33 years old on the alleged onset date of January 1, 2020. Tr. 95. 6 Mr. H. was able to graduate from high school with a GED. Tr. 63; 766. Mr. H. has 7 previously been employed as a stock clerk, a clothing sorter, a janitor, a cart

8 attendant, and a package truck driver’s helper. Tr. 63, 360, 516, 560, 706. 9 Mr. H. filed this claim for disability insurance benefits and supplemental 10 security income in December 2020. Tr. 263-84. The claim was denied initially and 11 upon reconsideration. Tr. 95-134, 135-80. Mr. H. and his mother testified at a

12 hearing in September 2023 concerning Mr. H.’s work history and his ability to 13 perform household chores. Tr. 58-90. On December 19, 2023, the ALJ issued an 14 unfavorable decision, Tr. 15-29, and the Appeals Council denied review. Tr. 1-6.

15 The matter is now before this Court pursuant to 42 U.S.C. § 405(g). 16 STANDARD OF REVIEW 17 This Court’s review of a final decision of the Commissioner of Social Security 18 is governed by 42 U.S.C. § 405(g). The scope of review is limited; the

19 Commissioner’s decision will be disturbed “only if it is not supported by substantial 20 evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 (9th Cir. 21 2012). If the evidence in the record “is susceptible to more than one 1 rational interpretation, [the Court] must uphold the ALJ’s findings if they are 2 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 3 F.3d 1104, 1111 (9th Cir. 2012). 4 Further, a district court “may not reverse an ALJ’s decision on account of an

5 error that is harmless.” Id. An error is harmless “where it is inconsequential to the 6 [ALJ’s] ultimate nondisability determination.” Id. at 1115 (quotation and citation 7 omitted). The party appealing the ALJ’s decision generally bears the burden of

8 establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 396, 409-10 (2009). 9 FIVE-STEP EVALUATION PROCESS 10 A claimant must satisfy two conditions to be considered “disabled” within the 11 meaning of the Social Security Act. First, the claimant must be “unable to engage in

12 any substantial gainful activity by reason of any medically determinable physical or 13 mental impairment which can be expected to result in death or which has lasted or 14 can be expected to last for a continuous period of not less than twelve months.” 42

15 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). Second, the claimant’s impairment must 16 be “of such severity that he is not only unable to do [his or her] previous work[,] but 17 cannot, considering [his or her] age, education, and work experience, engage in any 18 other kind of substantial gainful work which exists in the national economy.” 42

19 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3(B). 20 The Commissioner has established a five-step sequential analysis to determine 21 whether a claimant satisfies the above criteria. See 20 C.F.R. §§ 404.1520(a)(4)(i)- 1 (v), 416.920(a)(4)(i)-(v). At step one, if the claimant is engaged in “substantial 2 gainful activity,” the Commissioner must find that the claimant is not disabled. 20 3 C.F.R. §§ 404.1520(b), 416.920(b). At step two, the Commissioner considers the 4 severity of the claimant’s impairment. 20 C.F.R. §§ 404.1520(a)(4)(ii),

5 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of 6 impairments which significantly limits [his or her] physical or mental ability to do 7 basic work activities,” the analysis proceeds to step three. 20 C.F.R. §§ 404.1520(c),

8 416.920(c). At step three, the Commissioner compares the claimant’s impairment to 9 severe impairments recognized by the Commissioner to be so severe as to preclude a 10 person from engaging in substantial gainful activity. 20 C.F.R. §§ 11 404.1520(a)(4)(iii), 416.920(a)(4)(iii).

12 If the severity of the claimant’s impairment does not meet or exceed the 13 severity of the enumerated impairments, the Commissioner must assess the 14 claimant’s residual functional capacity (RFC), which is the claimant’s ability to

15 perform physical and mental work activities on a sustained basis despite his or her 16 limitations, 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). 17 At step four, the Commissioner considers whether, in view of the claimant’s 18 RFC, the claimant is capable of performing work that he or she has performed in the

19 past (past relevant work). 20 C.F.R. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). If not, 20 the analysis proceeds to step five and the Commissioner considers whether, in view 21 1 of the claimant’s RFC, the claimant is capable of performing other work in the 2 national economy. 20 C.F.R. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v). 3 The claimant bears the burden of proof at steps one through four above. 4 Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999). If the analysis proceeds to

5 step five, the burden shifts to the Commissioner to establish that (1) the claimant is 6 capable of performing other work; and (2) such work “exists in significant numbers 7 in the national economy.” 20 C.F.R.

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Houck v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houck-v-bisignano-waed-2025.