Kong v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedAugust 23, 2023
Docket3:22-cv-05999
StatusUnknown

This text of Kong v. Commissioner of Social Security (Kong v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kong v. Commissioner of Social Security, (W.D. Wash. 2023).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 VETH K., CASE NO. 3:22-CV-5999-DWC 11 Plaintiff, ORDER AFFIRMING DEFENDANT’S 12 v. DECISION TO DENY BENEFITS 13 COMMISSIONER OF SOCIAL SECURITY, 14 Defendant. 15

16 Plaintiff filed this action, pursuant to 42 U.S.C. § 405(g), for judicial review of 17 Defendant’s denial of Plaintiff's application for disability insurance benefits (“DIB”). Pursuant to 18 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73 and Local Rule MJR 13, the parties have 19 consented to have this matter heard by the undersigned Magistrate Judge. See Dkt. 4. 20 After considering the record, the Court concludes the Administrative Law Judge (“ALJ”) 21 did not violate Plaintiff’s constitutional rights; properly evaluated the medical opinion evidence, 22 Plaintiff’s testimony, and lay witness testimony; and properly assessed Plaintiff’s residual 23 24 1 functional capacity (“RFC”). Accordingly, the Court affirms the ALJ’s decision in finding 2 Plaintiff not disabled. 3 FACTUAL AND PROCEDURAL HISTORY 4 On November 6, 2013, Plaintiff filed for DIB, alleging disability as of April 24, 2013.

5 See Dkt. 14; Administrative Record (“AR”) 79-80, 90-91. The application was denied upon 6 initial administrative review and on reconsideration. See AR 87, 99. 7 ALJ S. Andrew Grace held a hearing on January 28, 2016 and issued a decision on 8 January 30, 2017 finding Plaintiff not disabled. AR 25-44, 49-75. After Plaintiff’s requested 9 review of the ALJ’s decision to the Appeals Council was denied, Plaintiff sought judicial review 10 in this Court. AR 15-20. On September 11, 2019, this Court reversed ALJ Grace’s decision and 11 remanded for further proceedings. AR 679-86. 12 On remand, ALJ Jo Hoenninger held a hearing on May 28, 2020 and issued a decision on 13 July 1, 2020, finding Plaintiff not disabled through September 20, 2018. AR 602-58. Plaintiff 14 again sought judicial review in this Court, and pursuant to the stipulation of both parties, this

15 Court remanded the case for further proceedings on August 18, 2021. AR 1458-62. 16 On remand, ALJ Hoenninger held three hearings. AR 1310-99. On the February 17, 2022 17 hearing, medical expert Dr. Abdolali Elmi testified. AR 1310-40. On the February 23, 2022 18 hearing, vocational expert (“VE”) Mark Harrington testified. AR 1341-73. The ALJ then held a 19 supplemental hearing on June 29, 2022 so VE Harrington could testify again. AR 1374-99. 20 Though Plaintiff was not present in the June 2022 hearing, her counsel attended. AR 1376. 21 On August 30, 2022 ALJ Hoenninger issued a decision again finding Plaintiff not 22 disabled. AR 1274-1309. In pertinent part, the ALJ found that from Plaintiff’s alleged onset date 23

24 1 through September 30, 2018, Plaintiff had the RFC to perform light work with several 2 limitations. AR 1284-85. Plaintiff now seeks judicial review of the ALJ’s August 2022 decision. 3 In Plaintiff’s Opening Brief, Plaintiff contends the ALJ: (1) violated her constitutional 4 right to procedural due process, (2) erred in evaluating the medical opinion evidence, (3) erred in

5 evaluating her subjective symptom testimony, (4) erred in evaluating lay witness evidence, (5) 6 and based step five findings on an erroneous RFC. Dkt. 14, p. 2. 7 STANDARD OF REVIEW 8 Pursuant to 42 U.S.C. § 405(g), this Court may set aside the Commissioner’s denial of 9 social security benefits if the ALJ’s findings are based on legal error or not supported by 10 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 11 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). 12 DISCUSSION 13 I. Whether the ALJ Violated Plaintiff’s Constitutional Rights 14 Plaintiff contends the ALJ violated her constitutional right to procedural due process.

15 Dkt. 14, p. 4. The Court rejects this argument. 16 Procedural due process requires a social security claimant receive “meaningful notice and 17 an opportunity to be heard before [her] claim for disability benefits may be denied.” Udd v. 18 Massanari, 245 F.3d 1096, 1099 (9th Cir. 2001) (citing Mathews v. Eldridge, 424 U.S. 319, 333 19 (1976)). 20 Plaintiff argues technical difficulties during the February 23, 2022 hearing resulted in her 21 counsel missing twenty minutes of the VE’s testimony. Dkt. 14, p. 4. During the February 23, 22 2022 hearing, Plaintiff’s counsel notified the ALJ he was not able to hear VE Harrington’s full 23 response to the ALJ’s first hypothetical. AR 1364. The record shows that after Plaintiff notified

24 1 the ALJ of the audio issue, the ALJ summarized the VE’s answers, and Plaintiff’s counsel made 2 no further objections. AR 1365-67. 3 Plaintiff also argues she was not able to testify during the June 2022 hearing. Dkt. 14, p. 4 4. The record shows the ALJ’s several attempts to contact Plaintiff were unsuccessful, and

5 Plaintiff’s counsel nonetheless agreed to proceed with the hearing even without Plaintiff present. 6 AR 1376-81. 7 Plaintiff also argues the ALJ erred during the June 2022 hearing by referring to an 8 interrogatory form that contained only VE Harrington’s signature and relying on evidence 9 missing from the record. Dkt. 14, p. 4. The form includes two hypotheticals regarding Plaintiff’s 10 RFC and a summary of the VE’s February 2022 testimony. AR 1808-15. The record indicates 11 Plaintiff’s counsel was aware of the contents of the interrogatory, as he inquired about the 12 summaries contained therein. AR 1383-84. The record also shows Plaintiff’s counsel made no 13 objections to the ALJ’s reference to the form during the hearing. See AR 1378-82, 1390. 14 Finally, Plaintiff argues that throughout the February 2022 and June 2022 hearings, “the

15 ALJ demonstrated an unwillingness to allow [her] attorney to question witnesses without 16 excessive interruption.” Dkt. 14, p. 4. However, during the February 17, 2022 hearing, Plaintiff’s 17 counsel was able to confirm with the medical expert his proposed limitations and was given an 18 opportunity to ask any further questions before the hearing ended. AR 1327-37. Similarly, during 19 the other hearings, the conversations between the ALJ and Plaintiff’s counsel while VE 20 Harrington was testifying were for clarification purposes, and Plaintiff’s counsel was always 21 provided an opportunity to follow up with any further questions. AR 1367-72, 1384-92. 22 Reviewing the transcript, it is clear neither Plaintiff’s counsel nor Plaintiff was 23 disadvantaged by the technical difficulties encountered in the hearings, the ALJ’s reference to

24 1 the interrogatory form, or the ALJ’s comments during the experts’ testimonies. Plaintiff fails to 2 show these issues were such harmful errors that they would be consequential to the ALJ’s 3 decision. See Stout v. Commissioner, Social Security Admin., 454 F.3d 1050, 1055 (9th Cir.

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Kong v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kong-v-commissioner-of-social-security-wawd-2023.