Jordan v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedMarch 22, 2022
Docket3:21-cv-08022
StatusUnknown

This text of Jordan v. Commissioner of Social Security Administration (Jordan 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
Jordan v. Commissioner of Social Security Administration, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9

10 Jeremiah Jordan, No. CV-21-08022-PCT-DGC

11 Plaintiff, ORDER

12 v.

13 Commissioner of Social Security Administration, 14 Defendant.

16 17 Plaintiff Jeremiah Jordan seeks judicial review under 42 U.S.C. § 405(g) of the 18 decision of an Administrative Law Judge (“ALJ”), which denied his claim for disability 19 insurance benefits and supplemental security income. Doc. 1. Plaintiff asserts both a 20 constitutional challenge and a merits challenge to the ALJ’s decision. Doc. 16. Plaintiff 21 claims that the decision is constitutionally defective because the Social Security Act 22 provision restricting the President’s authority to remove a Social Security Commissioner 23 without cause, 42 U.S.C. § 902(a)(3), violates the separation of powers doctrine. Id. at 6-9. 24 Plaintiff contends that this constitutional defect entitles him to a new hearing before a 25 different ALJ. Id. at 9. 26 With respect to the merits of the ALJ’s decision, Plaintiff claims that the ALJ erred 27 in two respects – finding that he could perform jobs that involve detailed instructions, and 28 rejecting his symptom testimony. Id. at 9-13. Plaintiff contends that the ALJ’s decision 1 should be vacated based on these alleged errors and the case remanded for an award of 2 benefits. Id. at 13-15. 3 For reasons stated below, the Court finds that while the removal provision in 4 § 902(a)(3) violates the separation of powers, Plaintiff is not entitled to a new hearing 5 because he has failed to show harm from that constitutional infirmity. The Court further 6 finds that Plaintiff’s substantive challenge to the ALJ’s decision is without merit. 7 I. Background. 8 Plaintiff applied for social security benefits in December 2018, alleging disability 9 as of November 15, 2016. Administrative Transcript (“Tr.”) 346-62. Plaintiff and a 10 vocational expert testified at a hearing before the ALJ on June 18, 2020. Tr. 159-82. On 11 July 1, 2020, the ALJ found Plaintiff not disabled within the meaning of the Social Security 12 Act. Tr. 16-40. This decision became the Commissioner’s final decision when the Appeals 13 Council denied review on December 7, 2020. Tr. 1-6. Plaintiff then commenced this action 14 for judicial review (Doc. 1), and the parties briefed the issues after receipt of the certified 15 administrative transcript (Docs. 12, 16, 20, 21). 16 II. Plaintiff’s Constitutional Challenge to the ALJ’s Decision. 17 “Generally, restrictions on Presidential removal powers of an agency director 18 violate the separation of powers and render an agency’s structure unconstitutional.” 19 Campbell v. Comm’r of Soc. Sec. Admin., No. CV-20-02048-PHX-JAT, 2022 WL 34677, 20 at *3 (D. Ariz. Jan. 4, 2022) (citing Seila Law LLC v. Consumer Fin. Prot. Bureau, 140 21 S. Ct. 2183 (2020) (finding that statutory tenure protection conferred on the CFPB director 22 violated the separation of powers); Collins v. Yellen, 141 S. Ct. 1761 (2021) (same with 23 respect a statutory provision requiring “cause” to remove the federal housing director)). 24 Section 902(a)(3) prohibits the President from removing the Social Security Commissioner 25 without cause – the Commissioner “may be removed from office only pursuant to a finding 26 by the President of neglect of duty or malfeasance in office.” 42 U.S.C. § 902(a)(3). 27 Plaintiff contends that § 902(a)(3) violates the separation of powers and he therefore 28 was deprived of a constitutionally valid adjudicatory process. Doc. 16 at 6-9 (citing 1 Seila Law). Plaintiff claims that this case should be remanded for a new hearing before an 2 ALJ who does not suffer from the “unconstitutional taint” of having previously heard and 3 decided this case with no lawful authority to do so. Id. at 9. 4 Defendant concedes that § 902(a)(3) violates the separation of powers. Doc. 20 at 4 5 (citing Office of Legal Counsel, U.S. Dep’t of Justice, Constitutionality of the Comm’r of 6 Soc. Sec.’s Tenure Prot., 2021 WL 2981542 (O.L.C. July 8, 2021) (“The President may 7 remove the Commissioner of Social Security at will notwithstanding the statutory 8 limitation on removal in 42 U.S.C. § 902(a)(3). The conclusion that the removal restriction 9 is constitutionally unenforceable does not affect the validity of the remainder of the 10 statute.”)); see also Lisa Y. v. Comm’r of Soc. Sec., No. C21-5207-BAT, 2021 WL 11 5177363, at *5 (W.D. Wash. Nov. 8, 2021) (“A straightforward application of Seila Law 12 and Collins dictates a finding that § 902(a)(3)’s removal provision violates separation of 13 powers. As in Seila Law and Collins, the Social Security Commissioner is a single officer 14 at the head of an administrative agency and removable only for cause.”). Defendant argues, 15 however, that the unconstitutionality of § 902(a)(3)’s removal provision provides no basis 16 for vacating the ALJ’s decision in this case because Plaintiff has not shown that the removal 17 provision has harmed him. Doc. 20 at 4 (citing Collins, 141 S. Ct. at 1787-89). The Court 18 agrees. 19 The Supreme Court held in Seila Law and Collins that statutory limitations on the 20 President’s ability to remove an Executive Branch agency head violate the separation of 21 powers. Seila Law, 140 S. Ct. at 2192; Collins, 141 S. Ct. at 1784. The Seila Law Court 22 further held that a removal provision is “severable from the other statutory provisions 23 bearing on the [agency’s] authority[,]” and “[t]he agency may therefore continue to 24 operate[.]” 140 S. Ct. at 2192. The Court confirmed this holding in Collins, explaining 25 that where the agency head was properly appointed, “the unlawfulness of the removal 26 provision does not strip the [agency head] of the power to undertake the other 27 responsibilities of his office,” and there was “no reason to regard any of the actions taken 28 by the [agency] . . . as void.” 141 S. Ct. at 1787-88 & n.23. The Collins Court concluded, 1 however, that this did not necessarily mean that the plaintiffs had no entitlement to relief 2 because it was still possible for the removal provision to inflict “compensable harm.” Id. 3 at 1788-89. The Court provided two examples: (1) where the President had attempted to 4 remove an agency head “but was prevented from doing so by a lower court decision holding 5 that he did not have ‘cause’ for removal”; or (2) where the President had expressed 6 displeasure with actions taken by an agency head and had asserted that he would remove 7 the agency head “if the statute did not stand in the way.” Id. at 1789. 8 Andrew Saul, who was appointed by former President Trump, was the Social 9 Security Commissioner in 2020 when the ALJ heard and decided Plaintiff’s claim for 10 benefits and when the Appeals Council denied review. See Soc. Sec. Admin., Historical 11 Information, https://www.ssa.gov/history/commissioners.html (noting that Mr. Saul served 12 as Commissioner from June 17, 2019 until July 9, 2021) (last visited Feb. 9, 2022); see also 13 Sean E. M. v. Kijakazi, No. 20-CV-07295-SK, 2022 WL 267406, at *2 & n.2 (N.D. Cal. 14 Jan. 28, 2022) (taking judicial notice of this fact). Plaintiff does not contend that the 15 President “sought to remove . . . Commissioner Saul or that either a Commissioner or the 16 President was involved [in] or even aware of [his] disability benefits claim. Therefore, he 17 [has] ‘failed to show how or why § 902(a)(3)’s removal clause possibly harmed him.’” 18 Sean E.

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Jordan v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jordan-v-commissioner-of-social-security-administration-azd-2022.