Hudnall v. Kijakazi

CourtDistrict Court, N.D. California
DecidedSeptember 25, 2023
Docket4:22-cv-02864
StatusUnknown

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

Bluebook
Hudnall v. Kijakazi, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 JOHN H., 7 Case No. 22-cv-02864-DMR Plaintiff, 8 v. ORDER ON CROSS MOTIONS FOR 9 SUMMARY JUDGMENT KILOLO KIJAKAZI, 10 Re: Dkt. Nos. 15, 16 Defendant. 11

12 Plaintiff John H. moves for summary judgment to reverse the Commissioner of the Social 13 Security Administration’s (the “Commissioner’s”) final administrative decision, which found 14 Plaintiff not disabled and therefore denied his application for benefits under Title II of the Social 15 Security Act, 42 U.S.C. § 401 et seq. [Docket No. 15.] The Commissioner cross-moves to affirm. 16 [Docket No. 16.] For the reasons stated below, the court denies Plaintiff’s motion and grants the 17 Commissioner’s cross motion. 18 I. PROCEDURAL HISTORY 19 Plaintiff filed an application for Social Security Disability Insurance (“SSDI”) benefits on 20 March 10, 2020, alleging disability beginning March 1, 2015. Administrative Record (“A.R.”) 21 166-67. The application was initially denied on June 3, 2020 and again on reconsideration on 22 October 7, 2020. A.R. 97-100, 105-111. An Administrative Law Judge (“ALJ”) held a telephonic 23 hearing on May 25, 2021 and issued an unfavorable decision on August 5, 2021. A.R. 17-35. The 24 ALJ determined that Plaintiff has the following severe impairment: major depressive disorder. 25 A.R. 23. The ALJ found that Plaintiff retains the following residual functional capacity (“RFC”):

26 [T]he claimant had the had the residual functional capacity to perform a full range of work at all exertional levels but with the following 27 nonexertional limitations: no exertional limits, is precluded from performing complex and detailed tasks but remains capable of environment, able to maintain concentration, persistence and pace for 1 two hour increments which presupposes that the morning break, lunch break and afternoon break would form the natural barriers for those 2 increments, no more than occasional work with coworkers and supervisors, and no work with the general public and no work on 3 assembly lines or similar production-paced type jobs. 4 A.R. 25. Relying on the opinion of a vocational expert (“VE”) who testified that an individual 5 with such an RFC could perform other jobs existing in the economy, including assembler, 6 production; office clerk paster; clerk/addresser; and packer, the ALJ concluded that Plaintiff is not 7 disabled. A.R. 33-35. 8 After the Appeals Council denied review, Plaintiff sought review in this court pursuant to 9 42 U.S.C. § 405(g). 10 II. ISSUES FOR REVIEW 11 1. Did the ALJ err in weighing the medical evidence? 12 2. Did the ALJ err in evaluating Plaintiff’s credibility? 13 3. Did the ALJ err in evaluating the lay witness testimony? 14 4. Did the ALJ err in finding that Plaintiff can perform the jobs identified by the VE? 15 III. STANDARD OF REVIEW 16 Pursuant to 42 U.S.C. § 405(g), this court has the authority to review a decision by the 17 Commissioner denying a claimant disability benefits. “This court may set aside the 18 Commissioner’s denial of disability insurance benefits when the ALJ’s findings are based on legal 19 error or are not supported by substantial evidence in the record as a whole.” Tackett v. Apfel, 180 20 F.3d 1094, 1097 (9th Cir. 1999) (citations omitted). Substantial evidence is evidence within the 21 record that could lead a reasonable mind to accept a conclusion regarding disability status. See 22 Richardson v. Perales, 402 U.S. 389, 401 (1971). It is more than a mere scintilla, but less than a 23 preponderance. See Saelee v. Chater, 94 F.3d 520, 522 (9th Cir. 1996) (internal citation omitted). 24 When performing this analysis, the court must “consider the entire record as a whole and may not 25 affirm simply by isolating a specific quantum of supporting evidence.” Robbins v. Soc. Sec. 26 Admin., 466 F.3d 880, 882 (9th Cir. 2006) (citation and quotation marks omitted). 27 If the evidence reasonably could support two conclusions, the court “may not substitute its 1 F.3d 1064, 1066 (9th Cir. 1997) (citation omitted). “Finally, the court will not reverse an ALJ’s 2 decision for harmless error, which exists when it is clear from the record that the ALJ’s error was 3 inconsequential to the ultimate nondisability determination.” Tommasetti v. Astrue, 533 F.3d 4 1035, 1038 (9th Cir. 2008) (citations and internal quotation marks omitted). 5 IV. DISCUSSION 6 A. The ALJ’s Weighing of the Medical Opinions 7 1. Legal Standard 8 Plaintiff filed an application for disability benefits after March 27, 2017. Therefore, the 9 court analyzes the claim under the Social Security Administration’s (“SSA”) regulations and 10 Social Security Rulings regarding the evaluation of medical opinion evidence that became 11 applicable as of that date. This includes SSR 96-2p, “Titles II and XVI: Giving Controlling 12 Weight to Treating Source Medical Opinions.” See Rescission of Soc. Sec. Rulings 96-2p, 96-5p, 13 & 06-3p, SSR 96-2P (S.S.A. Mar. 27, 2017). Under the new regulations, the SSA will no longer 14 give “any specific evidentiary weight, including controlling weight,” to medical opinions or prior 15 administrative medical findings, including those from treating physicians. 20 C.F.R. § 16 404.1520c(a); 20 C.F.R. § 416.920c(a). Instead, the SSA must evaluate the “persuasiveness” of 17 all medical opinions based on several factors, including supportability, consistency, the source’s 18 relationship with the claimant, length of the treatment relationship, frequency of examinations, 19 purpose of the treatment relationship, whether the source has examined the claimant, any 20 specialization, and other factors, such as “evidence showing a medical source has familiarity with 21 the other evidence in the claim or an understanding of [the SSA’s] disability program’s policies 22 and evidentiary requirements.” 20 C.F.R. 20 C.F.R. § 404.1520c(a), (c), 20 C.F.R. § 416.920c(a), 23 (c). The two most important factors in determining the persuasiveness of medical opinions are 24 consistency and supportability. Woods v. Kijakazi, 32 F.4th 785, 791 (9th Cir. 2022) (citing 20 25 C.F.R. § 404.1520c(a)); see also 20 C.F.R. § 416.920c(a). 26 “Although the regulations eliminate the ‘physician hierarchy,’ deference to specific 27 medical opinions, and assigning ‘weight’ to a medical opinion, the ALJ must still ‘articulate how 1 opinions.” V.W. v. Comm’r of Soc. Sec., No. 18-CV-07297-JCS, 2020 WL 1505716, at *14 (N.D. 2 Cal. Mar. 30, 2020). “[A]n ALJ cannot reject an examining or treating doctor’s opinion as 3 unsupported or inconsistent without providing an explanation supported by substantial evidence.” 4 Woods, 32 F.4th at 792. “The agency must ‘articulate . .

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