Howatt v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedMarch 29, 2024
Docket2:23-cv-00308
StatusUnknown

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

Bluebook
Howatt v. Commissioner of Social Security Administration, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Molly Howatt, No. CV-23-00308-PHX-DJH

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Plaintiff Molly Howatt (“Plaintiff”) seeks judicial review of a decision by the Social 16 Security Administration (“SSA”) Commissioner (the “Commissioner”) denying her 17 application for Supplemental Security Disability Insurance (“SSDI”) benefits under the 18 Social Security Act, 42 U.S.C. § 301 et seq. (the “Act”). (Doc. 1). Plaintiff filed her 19 Opening Brief (Doc. 11), the Commissioner filed a Response (Doc. 13), and Plaintiff filed 20 a Reply (Doc. 14). Upon review of the briefs and the Administrative Record 21 (Doc. 8 “AR”), the Court affirms the Administrative Law Judge’s (“ALJ”) 22 November 23, 2021, decision (AR at 12–25). 23 I. Background 24 On February 26, 2020, Plaintiff filed an application for SSDI benefits under Title II 25 of the Act, alleging a disability onset date of June 1, 2019. (Id. at 15). Plaintiff was fifty 26 years old at the time of her alleged onset date and has a high school education. (Id. at 34– 27 25). Her past relevant work includes employment as a receptionist in a medical clinic. 28 (Id. at 34). Plaintiff claims she is unable to work due to enlarged heart, possible lymphoma, 1 Sjogren’s syndrome, hypothyroid, and residuals from radiation and chemo for breast 2 cancer. (Id. at 61–62). 3 Plaintiff’s claims were initially denied on August 7, 2020, and upon reconsideration 4 on April 15, 2021. (Id. at 15). After holding a hearing, the ALJ issued an unfavorable 5 decision on November 23, 2021, (AR at 12–25) (the “November Decision”). 6 II. The ALJ’s Five Step Process 7 To be eligible for Social Security benefits, a claimant must show an “inability to 8 engage in any substantial gainful activity by reason of any medically determinable physical 9 or mental impairment which can be expected to result in death or which has lasted or can 10 be expected to last for a continuous period of not less than 12 months.” 11 42 U.S.C. § 423(d)(1)(A); see also Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999). 12 The ALJ follows a five-step process1 to determine whether a claimant is disabled under the 13 Act: 14 The five-step process for disability determinations begins, at the first and second steps, by asking whether a claimant is engaged in “substantial gainful 15 activity” and considering the severity of the claimant’s impairments. 16 See 20 C.F.R. § 416.920(a)(4)(i)–(ii). If the inquiry continues beyond the second step, the third step asks whether the claimant’s impairment or 17 combination of impairments meets or equals a listing under 18 20 C.F.R. pt. 404, subpt. P, app. 1 and meets the duration requirement. See id. § 416.920(a)(4)(iii). If so, the claimant is considered disabled and 19 benefits are awarded, ending the inquiry. See id. If the process continues 20 beyond the third step, the fourth and fifth steps consider the claimant’s “residual functional capacity”2 in determining whether the claimant can still 21 do past relevant work or make an adjustment to other work. 22 See id. § 416.920(a)(4)(iv)–(v). 23 Kennedy v. Colvin, 738 F.3d 1172, 1175 (9th Cir. 2013); see also 20 C.F.R. § 404.1520(a)– 24 (g). If the ALJ determines no such work is available, the claimant is disabled. 25 20 C.F.R. § 404.1520(a)(4)(v).

26 1 The claimant bears the burden of proof on the first four steps, but the burden shifts to the Commissioner at step five. Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999). 27 2 A claimant’s residual functional capacity is defined as their maximum ability to do 28 physical and mental work activities on a sustained basis despite limitations from their impairments. See 20 C.F.R. §§ 404.1545(a), 404.1520(e), 416.920(e). 1 The ALJ’s findings in the November Decision are as follows: 2 At step one, the ALJ found that Plaintiff met the insured status requirements of the 3 Act on September 30, 2020, and that she has not engaged in substantial gainful activity 4 since June 1, 2019, her alleged onset date. (AR. at 14). At step two, the ALJ found Plaintiff 5 has the following severe impairments: coronary artery disease with abdominal aortic 6 aneurysm, lymphadenopathy, and Sjogren’s syndrome. (Id. at 18 (citing 20 C.F.R. § 7 416.920(c)). At step three, she determined Plaintiff does not have an impairment or 8 combination of impairments that meets or medically equals an impairment listed in 9 Appendix 1 to Subpart P of 20 C.F.R. Part 404. (Id. at 18–19). 10 At step four, the ALJ found Plaintiff had the residual functional capacity (“RFC”) 11 through her date last insured to perform sedentary work3 “with no climbing of ladders, 12 ropes, or scaffolds; occasional climbing of ramps and stairs; and she would need to avoid 13 exposure to workplace hazards such as heights and heavy machinery.” (Id. at 19). In 14 determining Plaintiff’s RFC, the ALJ stated she “considered all [of Plaintiff’s] symptoms 15 and the extent to which these symptoms can reasonably be accepted as consistent with the 16 objective medical evidence and other evidence, based on the requirements of 20 § C.F.R. 17 404.1529 and [Social Security Ruling] 16-3p.” (Id.) The ALJ also considered the medical 18 opinions and prior administrative medical findings in accordance with the requirements of 19 20 C.F.R. § 404.1520c. (Id.) Given her RFC assessment, the ALJ determined Plaintiff 20 was capable of performing past relevant work as a receptionist and a medical secretary. 21 (Id. at 24–25). The ALJ therefore did not reach step five and deemed Plaintiff not disabled 22 from June 1, 2019, her alleged onset date, through September 30, 2020, her last date 23 insured. (Id. at 25 (citing 20 C.F.R. § 404.1520(f)). 24 The SSA Appeals Council denied Plaintiff’s request for review of the 25 November Decision, thus adopting the Decision as the agency’s final decision. (Id. at 1–

26 3 “Sedentary work involves lifting no more than 10 pounds at a time and occasionally lifting or carrying articles like docket files, ledgers, and small tools. Although a sedentary job is 27 defined as one which involves sitting, a certain amount of walking and standing is often necessary in carrying out job duties. Jobs are sedentary if walking and standing are 28 required occasionally and other sedentary criteria are met.” 20 C.F.R. §§ 404.1567(a); 416.967(a). 1 3). This appeal followed. On February 20, 2023, Plaintiff filed a Complaint under 2 42 U.S.C. §§ 405

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Howatt v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howatt-v-commissioner-of-social-security-administration-azd-2024.