Irene Reza v. Andrew Saul

CourtDistrict Court, C.D. California
DecidedJuly 30, 2020
Docket2:19-cv-04832
StatusUnknown

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

Bluebook
Irene Reza v. Andrew Saul, (C.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 IRENE R.,1 Case No. 2:19-cv-04832-AFM 12 Plaintiff, MEMORANDUM OPINION AND 13 v. ORDER AFFIRMING DECISION OF COMMISSIONER 14 ANDREW SAUL, 15 Commissioner of Social Security, 16 Defendant. 17 18 Plaintiff filed this action seeking review of the Commissioner’s final decision 19 denying her application for Social Security disability insurance benefits. In 20 accordance with the Court’s case management order, the parties have filed 21 memorandum briefs addressing the merits of the disputed issues. This matter is now 22 ready for decision. 23 BACKGROUND 24 Plaintiff first applied for disability insurance benefits on January 17, 2006, 25 alleging that she became disabled on May 11, 2000. (Administrative Record [“AR”] 26 27 1 Plaintiff’s name has been partially redacted in accordance with Federal Rule of Civil Procedure 5.2(c)(2)(B) and the recommendation of the Committee on Court Administration and Case 28 Management of the Judicial Conference of the United States. 1 122.) On May 13, 2008, Administrative Law Judge (“ALJ”) Joel B. Martinez found 2 that Plaintiff retained the residual functional capacity (“RFC”) to perform a range of 3 light work. (AR 125.) ALJ Martinez determined that Plaintiff could perform work 4 existing in significant numbers in the national economy. (AR 130.) Accordingly, ALJ 5 Martinez concluded that Plaintiff was not disabled. (AR 131.) The Appeals Council 6 denied review. (AR 132-134.) ALJ Martinez’s decision subsequently became the 7 final decision of the Commissioner. 8 On September 28, 2015, Plaintiff filed a new application for disability 9 insurance benefits. (AR 257-258.) Plaintiff alleged the same disability onset date as 10 alleged in her previous application: May 11, 2000. (AR 257.) Plaintiff’s claim was 11 denied. (AR 148-152.) A hearing took place on February 23, 2018 before ALJ 12 Edward T. Bauer. (AR 36.) Both Plaintiff, who was represented by counsel, and a 13 vocational expert (“VE”) testified at the hearing. (AR 38-87.) 14 In a decision dated May 21, 2018, ALJ Bauer found that Plaintiff did not show 15 changed circumstances and, as a result, failed to rebut the presumption of continuing 16 non-disability. (AR 10-13.) Nevertheless, ALJ Bauer also evaluated the evidence 17 proffered by Plaintiff and made his own findings. (AR 13-16.) ALJ Bauer determined 18 that Plaintiff failed to identify or submit new and material evidence to demonstrate 19 that she was disabled on or before her date last insured. (AR 13-16.) ALJ Bauer 20 therefore concluded that ALJ Martinez’s decision was binding. (AR 16.) The Appeals 21 Council denied Plaintiff’s request for review, thereby rendering ALJ Bauer’s 22 decision the final decision of the Commissioner. (AR 1-6.) 23 DISPUTED ISSUE 24 Whether the ALJ properly found that Plaintiff had not overcome the 25 presumption of continuing non-disability. 26 STANDARD OF REVIEW 27 Under 42 U.S.C. § 405(g), this Court reviews the Commissioner’s decision to 28 determine whether the Commissioner’s findings are supported by substantial 1 evidence and whether the proper legal standards were applied. See Treichler v. 2 Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1098 (9th Cir. 2014). Substantial 3 evidence means “more than a mere scintilla” but less than a preponderance. See 4 Richardson v. Perales, 402 U.S. 389, 401 (1971); Lingenfelter v. Astrue, 504 F.3d 5 1028, 1035 (9th Cir. 2007). Substantial evidence is “such relevant evidence as a 6 reasonable mind might accept as adequate to support a conclusion.” Richardson, 402 7 U.S. at 401. This Court must review the record as a whole, weighing both the 8 evidence that supports and the evidence that detracts from the Commissioner’s 9 conclusion. Lingenfelter, 504 F.3d at 1035. Where evidence is susceptible of more 10 than one rational interpretation, the Commissioner’s decision must be upheld. See 11 Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007). 12 DISCUSSION 13 I. Relevant Law 14 The principles of res judicata apply to administrative decisions. Chavez v. 15 Bowen, 844 F.2d 691, 693 (9th Cir. 1988). Thus, an ALJ’s determination that a 16 claimant is not disabled creates a presumption that the claimant continued to be able 17 to work after that date. Vasquez v. Astrue, 572 F.3d 586, 597 (9th Cir. 2009). An 18 ALJ’s findings cannot be reconsidered by a subsequent ALJ unless the claimant 19 shows “changed circumstances” –that is, new and material information not presented 20 to the first judge. See Stubbs-Danielson v. Astrue, 539 F.3d 1169, 1173 (9th Cir. 21 2008); Lester v. Chater, 81 F.3d 821, 827 (9th Cir. 1995). Following Chavez, the 22 Social Security Administration adopted Acquiescence Ruling97-4(9) to explain how 23 it would apply Chavez within the Ninth Circuit. Pursuant to that ruling, an ALJ must 24 apply a presumption of continuing non-disability, which a claimant may rebut “by 25 showing a ‘changed circumstance’ affecting the issue of disability with respect to the 26 unadjudicated period.” AR 97-4(9), 1997 WL 742758, at *3. “Changed 27 circumstances” include the existence of a new impairment not considered in the 28 previous application, a change in the claimant’s age category, or an increase in the 1 severity of the claimant’s impairment. See Lester, 81 F.3d at 827; Chavez, 844 F.2d 2 at 693; see also AR 97-4(9). 3 II. ALJ Bauer’s Decision 4 ALJ Bauer began by acknowledging the prior ALJ’s decision, which 5 concluded that Plaintiff retained the capacity to perform a range of light work. (AR 6 10.) ALJ Bauer determined that the Chavez presumption of continuing non-disability 7 applies to Plaintiff because her case meets the following criteria set forth in Social 8 Security Acquiescence Ruling 97-4(9): “the adjudicator is deciding a subsequent 9 disability claim with an unadjudicated period arising under the same title of the Act 10 as a prior disability claim;” an ALJ previously decided that Plaintiff is not disabled 11 and that ALJ’s decision became final; the previous ALJ’s decision “was based on the 12 claimant’s work activity or earnings, an evaluation of medical evidence of the 13 claimant’s impairments, or a consideration of both medical and vocational factors;” 14 Plaintiff resided in California at the time of the subsequent claim. (AR 10-11.) Thus, 15 ALJ Bauer concluded that Plaintiff was required to rebut the presumption of a 16 continuing non-disability before she could be found disabled.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Orn v. Astrue
495 F.3d 625 (Ninth Circuit, 2007)
Stubbs-Danielson v. Astrue
539 F.3d 1169 (Ninth Circuit, 2008)
Vasquez v. Astrue
572 F.3d 586 (Ninth Circuit, 2009)
Lester v. Chater
81 F.3d 821 (Ninth Circuit, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Irene Reza v. Andrew Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/irene-reza-v-andrew-saul-cacd-2020.