Latham v. O'Malley

CourtDistrict Court, E.D. Washington
DecidedSeptember 13, 2024
Docket4:22-cv-05156
StatusUnknown

This text of Latham v. O'Malley (Latham 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
Latham v. O'Malley, (E.D. Wash. 2024).

Opinion

1 2 U.S. F DIL ISE TD R I IN C TT H CE O URT EASTERN DISTRICT OF WASHINGTON

Sep 13, 2024 3

SEAN F. MCAVOY, CLERK 4

7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF WASHINGTON 9

10 RYAN L., 11 No: 4:22-cv-05156-LRS Plaintiff, 12 v. ORDER AFFIRMING THE 13 COMMISSIONER’S DECISION MARTIN O’MALLEY, 14 COMMISSIONER OF SOCIAL SECURITY,1 15

16 Defendant.

17 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 BEFORE THE COURT are the parties’ briefs. ECF Nos. 12, 18. This 2 matter was submitted for consideration without oral argument. Plaintiff is 3 represented by attorney Chad Hatfield. Defendant is represented by Special 4 Assistant United States Attorney Thomas Chandler. The Court, having reviewed the

5 administrative record and the parties’ briefing, is fully informed. For the reasons 6 discussed below, Plaintiff’s brief, ECF No. 12, is denied and Defendant’s brief, ECF 7 No. 18, is granted.

8 JURISDICTION 9 Plaintiff Ryan L.3 (Plaintiff), filed for disability insurance benefits (DIB) on 10 April 6, 2019, alleging an onset date of May 8, 2018. Tr. 221-24. Benefits were 11 denied initially, Tr. 115-17, and upon reconsideration, Tr. 119-21. Plaintiff

12 appeared at a hearing before an administrative law judge (ALJ) on July 18, 2022. 13 Tr. 44-76. On August 12, 2022, the ALJ issued an unfavorable decision, Tr. 13-36. 14

16 2 Plaintiff’s brief is labeled as a Motion for Summary Judgment. ECF No. 12. The 17 supplemental rules for Social Security actions under 42 U.S.C. § 405(g) went into 18 effect on December 1, 2022; Rule 5 and Rule 6 state the actions are presented as 19 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 The Appeals Council denied review on October 4, 2022. Tr. 1-6. The matter is now 2 before this Court pursuant to 42 U.S.C. § 405(g). 3 BACKGROUND 4 The facts of the case are set forth in the administrative hearings and

5 transcripts, the ALJ’s decision, and the briefs of Plaintiff and the Commissioner, and 6 are therefore only summarized here. 7 Plaintiff was born in 1985 and 32 years old on the alleged onset date. Tr. 30.

8 He graduated from high school and attended some college. Tr. 51. He served in the 9 Marines from January 2004 until August 2007. Tr. 50-51. He last worked for an 10 auto dealer as a parts clerk in the service department. Tr. 49. He used to have 11 seizures once or twice a month until May 2019 when he stopped drinking. Tr. 51-

12 52. In May 2018, he had a seizure and fell off a ladder. At that point his memory 13 “got really bad.” Tr. 52. It would take a couple of days to recover from a seizure. 14 Tr. 53. He continues to have episodes of “spacing out” or “blacking out” three to

15 four times a day. Tr. 53-55. He has problems with his memory, understanding, and 16 communicating, as well as problems with his vision. Tr. 55, 60. 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). If the claimant suffers from 17 “any impairment or combination of impairments which significantly limits [his or 18 her] physical or mental ability to do basic work activities,” the analysis proceeds to

19 step three. 20 C.F.R. § 404.1520(c).

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