King v. O'Malley

CourtDistrict Court, E.D. Washington
DecidedApril 8, 2024
Docket2:22-cv-00163
StatusUnknown

This text of King v. O'Malley (King v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
King v. O'Malley, (E.D. Wash. 2024).

Opinion

3 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 Apr 08, 2024 5 SEAN F. MCAVOY, CLERK UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7

9 ANGELA HELEN K., No: 2:22-cv-00163-LRS 10 Plaintiff,

11 v. ORDER AFFIRMING THE COMMISSIONER’S DECISION 12 MARTIN O’MALLEY, COMMISSIONER OF SOCIAL 13 SECURITY,1

14 Defendant. 15

16 BEFORE THE COURT are the parties’ briefs. ECF Nos. 10, 11.2 This 17 matter was submitted for consideration without oral argument. Plaintiff is 18

19 1 Martin O’Malley became the Commissioner of Social Security on December 20, 20 2023. Pursuant to Rule 25(d) of the Rules of Civil Procedure, Martin O’Malley is 21 substituted for Kilolo Kijakazi as the Defendant in this suit. 1 represented by attorney Asa LaMusga. Defendant is represented by Special 2 Assistant United States Attorney Sarah Moum. The Court, having reviewed the 3 administrative record and the parties’ briefing, is fully informed. For the reasons 4 discussed below, Plaintiff’s brief, ECF No. 10, is denied and Defendant’s brief, ECF

5 No. 11, is granted. 6 JURISDICTION 7 Plaintiff Angela Helen K. 3 (Plaintiff), filed for disability insurance benefits

8 (DIB) on October 2, 2019, alleging an onset date of October 1, 2014, which was 9 amended to April 26, 2018, at the hearing. Tr. 64, 213-14. Benefits were denied 10 initially, Tr. 127-29, and upon reconsideration, Tr. 135-40. Plaintiff appeared at a 11 hearing before an administrative law judge (ALJ) on March 8, 2021. Tr. 58-93. On

12 May 3, 2021, the ALJ issued an unfavorable decision, Tr. 31-50. The Appeals 13 Council denied review on April 29, 2022. Tr. 1-7. The matter is now before this 14 Court pursuant to 42 U.S.C. § 405(g).

16 2 The parties’ briefs are each labeled as a Motion for Summary Judgment. ECF No. 17 10, 11. The supplemental rules for Social Security actions under 42 U.S.C. § 18 405(g) went into effect on December 1, 2022; Rule 5 and Rule 6 state the actions 19 are presented as briefs rather than motions. Fed. R. Civ. P. Supp. Soc. Sec. R. 5, 6. 20 3 The court identifies a plaintiff in a social security case only by the first name and 21 last initial in order to protect privacy. See Local Civil Rule 5.2(c). 1 BACKGROUND 2 The facts of the case are set forth in the administrative hearings and 3 transcripts, the ALJ’s decision, and the briefs of Plaintiff and the Commissioner, and 4 are therefore only summarized here.

5 Plaintiff was 47 years old at the time of the hearing. Tr. 65. She has a GED 6 and completed a trade school program for administrative computer specialist. Tr. 7 67. She last worked in 2014 at a rent-to-own furniture store doing set-up, sales, and

8 scheduling and making deliveries. Tr. 67. She quit that job because she was 9 required to lift furniture and was not able to do so. Tr. 68. She also has work 10 experience in farm and ranch retail, home improvement retail, as an IT manager, and 11 performing technical support for web hosting services. Tr. 69-72.

12 Plaintiff has pain originating from her lower back. Tr. 79. She testified that 13 her doctor said a disc is pinching on the nerve root. Tr. 79. On good days, she has 14 difficulty walking. Tr. 72. Her right leg and toes go numb if she sits too long. Tr.

15 76. She feels pressure in her lower back which radiates down the back of her leg. 16 Tr. 76-77. Sometimes she loses bladder control. Tr. 79. 17 STANDARD OF REVIEW 18 A district court’s review of a final decision of the Commissioner of Social

19 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 20 limited; the Commissioner’s decision will be disturbed “only if it is not supported by 21 substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 1 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a reasonable 2 mind might accept as adequate to support a conclusion.” Id. at 1159 (quotation and 3 citation omitted). Stated differently, substantial evidence equates to “more than a 4 mere scintilla[,] but less than a preponderance.” Id. (quotation and citation omitted).

5 In determining whether the standard has been satisfied, a reviewing court must 6 consider the entire record as a whole rather than searching for supporting evidence in 7 isolation. Id.

8 In reviewing a denial of benefits, a district court may not substitute its 9 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 1156 10 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 11 rational interpretation, [the court] must uphold the ALJ’s findings if they are

12 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 13 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an ALJ’s 14 decision on account of an error that is harmless.” Id. An error is harmless “where it

15 is inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1115 16 (quotation and citation omitted). The party appealing the ALJ’s decision generally 17 bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 18 396, 409-10 (2009).

19 FIVE-STEP EVALUATION PROCESS 20 A claimant must satisfy two conditions to be considered “disabled” within the 21 meaning of the Social Security Act. First, the claimant must be “unable to engage in 1 any substantial gainful activity by reason of any medically determinable physical or 2 mental impairment which can be expected to result in death or which has lasted or 3 can be expected to last for a continuous period of not less than twelve months.” 42 4 U.S.C. §§ 423(d)(1)(A). Second, the claimant’s impairment must be “of such

5 severity that he is not only unable to do his previous work[,] but cannot, considering 6 his age, education, and work experience, engage in any other kind of substantial 7 gainful work which exists in the national economy.” 42 U.S.C. § 423(d)(2)(A).

8 The Commissioner has established a five-step sequential analysis to determine 9 whether a claimant satisfies the above criteria. See 20 C.F.R. § 404.1520(a)(4)(i)- 10 (v). At step one, the Commissioner considers the claimant’s work activity. 20 11 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in “substantial gainful

12 activity,” the Commissioner must find that the claimant is not disabled. 20 C.F.R. § 13 404.1520(b). 14 If the claimant is not engaged in substantial gainful activity, the analysis

15 proceeds to step two. At this step, the Commissioner considers the severity of the 16 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii).

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King v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-omalley-waed-2024.