Jackson v. Saul

CourtDistrict Court, D. Nevada
DecidedMarch 10, 2022
Docket2:20-cv-02236
StatusUnknown

This text of Jackson v. Saul (Jackson v. Saul) 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
Jackson v. Saul, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 BETTY JACKSON, Case No.: 2:20-cv-02236-CSD

4 Plaintiff Order

5 v. Re: ECF Nos. 21, 22

6 KILOLO KIJAKAZI, Acting Commissioner of Social 7 Security Administration,1

8 Defendant

9 10 Before the court is Plaintiff's motion for reversal and/or remand. (ECF No. 21. ) The 11 Acting Commissioner filed a cross-motion to affirm and opposition to Plaintiff's motion. (ECF 12 Nos. 22, 23.) Plaintiff filed a reply. (ECF No. 24.) 13 After a thorough review, Plaintiff’s motion is denied, and the Acting Commissioner’s 14 cross-motion to affirm is granted. 15 I. BACKGROUND 16 In November of 2017, Plaintiff completed an application for supplemental security 17 income (SSI) under Title XVI of the Social Security Act, alleging disability beginning on 18 June 15, 2017. (Administrative Record (AR) 170-175.) The applications were denied initially 19 and on reconsideration. (AR 99-102, 107-109.) 20 Plaintiff requested a hearing before an administrative law judge (ALJ). ALJ Cynthia 21 Hoover held a hearing on February 24, 2020. (AR 30-62.) Plaintiff, who was represented by 22

1 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Under 23 Federal Rule of Civil Procedure 25(d), she is automatically substituted as a party for her predecessor. 1 counsel, appeared and testified on her own behalf at the hearing. Testimony was also taken from 2 a vocational expert (VE). On May 6, 2020, the ALJ issued a decision finding Plaintiff not 3 disabled. (AR 12-25.) Plaintiff requested review, and the Appeals Council denied the request, 4 making the ALJ's decision the final decision. (AR 1-3.)

5 Plaintiff then commenced this action for judicial review under 42 U.S.C. § 405(g). 6 Plaintiff first argues the final decision arose from an unconstitutional administrative process 7 because the removal restriction on the Commissioner of the Social Security Administration 8 (SSA) is unconstitutional. Therefore, Plaintiff alleges relevant agency actions taken during the 9 Commissioner’s tenure were also unconstitutional. As a result, Plaintiff contends she is entitled 10 to remand for a new hearing and administrative decision. Second, Plaintiff argues that the ALJ 11 failed to articulate clear and convincing reasons for discounting Plaintiff’s subjective complaints. 12 The Acting Commissioner, on the other hand, argues that Plaintiff’s separation of powers 13 argument does not entitle her to a rehearing of her disability claim, and the ALJ properly 14 discounted Plaintiff’s subjective symptom testimony.

15 II. STANDARDS 16 A. Five-Step Evaluation of Disability 17 Under the Social Security Act, "disability" is the inability to engage "in any substantial 18 gainful activity by reason of any medically determinable physical or mental impairment which 19 can be expected to result in death or which has lasted or can be expected to last for a continuous 20 period of not less than 12 months." 42 U.S.C. § 1382c(a)(3)(A). A claimant is disabled if his or 21 her physical or mental impairment(s) are so severe as to preclude the claimant from doing not 22 only his or her previous work but also, any other work which exists in the national economy, 23 considering his age, education and work experience. 42 U.S.C. § 1382c(a)(3)(B). 1 The Commissioner has established a five-step sequential process for determining whether 2 a person is disabled. 20 C.F.R. §404.1520 and § 416.920; see also Bowen v. Yuckert, 482 U.S. 3 137, 140-41 (1987). In the first step, the Commissioner determines whether the claimant is 4 engaged in "substantial gainful activity." If so, a finding of nondisability is made, and the claim

5 is denied. 20 C.F.R. § 404.152(a)(4)(i), (b); § 416.920(a)(4)(i); Yuckert, 482 U.S. at 140. If the 6 claimant is not engaged in substantial gainful activity, the Commissioner proceeds to step two. 7 The second step requires the Commissioner to determine whether the claimant's 8 impairment or combination of impairments are "severe." 20 C.F.R. § 404.1520(a)(4)(ii), (c) and 9 § 416.920(a)(4)(ii), (c); Yuckert, 482 U.S. at 140-41. An impairment is severe if it significantly 10 limits the claimant's physical or mental ability to do basic work activities. Id. If the claimant has 11 an impairment that is severe, the Commissioner proceeds to step three. 12 In the third step, the Commissioner looks at a number of specific impairments listed in 13 20 C.F.R. Part 404, Subpart P, Appendix 1 (Listed Impairments) and determines whether the 14 claimant's impairment(s) meets or is the equivalent of one of the Listed Impairments. 20 C.F.R.

15 § 404.1520(a)(4)(iii), (d) and § 416.920(a)(4)(iii), (d). The Commissioner presumes the Listed 16 Impairments are severe enough to preclude any gainful activity, regardless of age, education or 17 work experience. 20 C.F.R. § 404.1525(a), § 416.925(a). If the claimant's impairment meets or 18 equals one of the Listed Impairments, and is of sufficient duration, the claimant is conclusively 19 presumed disabled. 20 C.F.R. § 404.1520(a)(4)(iii), (d), § 416.920(a)(4)(iii), (d). If the claimant's 20 impairment is severe, but does not meet or equal one of the Listed Impairments, the 21 Commissioner proceeds to step four. Yuckert, 482 U.S. at 141. 22 At step four, the Commissioner determines whether the claimant can still perform "past 23 relevant work." 20 C.F.R. § 404.1520(a)(4)(iv), (e), (f) and § 416.920(a)(4)(iv), (e), (f). Past 1 relevant work is that which a claimant performed in the last 15 years, which lasted long enough 2 for him or her to learn to do it and was substantial gainful activity. 20 C.F.R. § 404.1565(a) and § 3 416.920(a). 4 In making this determination, the Commissioner assesses the claimant's residual

5 functional capacity (RFC) and the physical and mental demands of the work previously 6 performed. See id.; 20 C.F.R. § 404.1520(a)(4)(v), § 416.920(a)(4)(v); see also Berry v. Astrue, 7 622 F.3d 1228, 1231 (9th Cir. 2010). RFC is what the claimant can still do despite his or her 8 limitations. 20 C.F.R. § 404.1545 and § 416.945. In determining the RFC, the Commissioner 9 must assess all evidence, including the claimant's and others' descriptions of the limitations, and 10 medical reports, to determine what capacity the claimant has for work despite his or her 11 impairments. 20 C.F.R.

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Jackson v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-saul-nvd-2022.