Le v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJuly 17, 2023
Docket2:22-cv-01249
StatusUnknown

This text of Le v. Commissioner of Social Security (Le 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
Le v. Commissioner of Social Security, (W.D. Wash. 2023).

Opinion

6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT TACOMA 8 ANH L., 9 Plaintiff, CASE NO. C22-1249-TLF 10 v. 11 ORDER RE: SOCIAL SECURITY COMMISSIONER OF SOCIAL DISABILITY APPEAL 12 SECURITY,

13 Defendant.

14 Plaintiff filed this action pursuant to 42 U.S.C. § 405(g) for judicial review of the 15 Commissioner’s denial of Plaintiff’s applications for disability benefits. Pursuant to 28 16 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and Local Rule MJR 13, the parties 17 have consented to proceed before the undersigned Magistrate Judge. 18 Having considered the ALJ’s decision, the administrative record (AR), and all 19 memoranda of record, this matter is REVERSED and REMANDED for further 20 administrative proceedings. 21 I. BACKGROUND 22 Plaintiff filed an application for Disability Insurance Benefits (DIB) and an 23 application for Supplemental Security Income (SSI) on January 28, 2019, alleging 1 disability beginning December 31, 2016. AR 17. After the applications were denied at the 2 initial level and on reconsideration, Plaintiff requested a hearing before an Administrative 3 Law Judge (ALJ). The ALJ held a hearing on March 29, 2021, and took testimony from

4 Plaintiff and a vocational expert (VE). AR 36–55. On May 3, 2021, the ALJ issued a 5 decision finding Plaintiff not disabled. AR 17–31. The Appeals Council denied Plaintiff’s 6 request for review on April 19, 2022, making the ALJ’s decision the final decision of the 7 Commissioner. AR 7–11; see 20 C.F.R. §§ 404.981, 416.1481. Plaintiff appeals the denial 8 of disability benefits to this Court. 9 II. STANDARD OF REVIEW 10 Pursuant to 42 U.S.C. § 405(g), the Court may set aside the Commissioner’s denial 11 of disability benefits if it is based on legal error or not supported by substantial evidence 12 in the record. See Woods v. Kijakazi, 32 F.4th 785, 788 (9th Cir. 2022). 13 III. THE ALJ’S FINDINGS

14 The Commissioner follows a five-step sequential evaluation process for 15 determining whether a claimant is disabled. See 20 C.F.R. §§ 404.1520, 416.920. At 16 steps one through three, the ALJ found Plaintiff had not engaged in substantial gainful 17 activity for a continuous 12-month period,1 has one or more severe impairments, and 18 does not have an impairment or combination of impairments that meet or equal the criteria 19 of a listed impairment since the alleged onset date. AR 19–23. 20 At step four, the ALJ found Plaintiff has the residual functional capacity (RFC) to 21 perform light work, as defined in 20 C.F.R. §§ 404.1567(b) and 416.967(b), with the 22

23 1 The ALJ found Plaintiff engaged in substantial gainful activity during the second and third quarter of 2018. AR 19. 1 following limitations: 2 the claimant can occasionally lift twenty pounds, frequently lift ten pounds; stand/walk for a total of about six hours and sit 3 for about six hours in an eight-hour day; never climb ladders, ropes, and scaffolds; frequently climb ramps and stairs; 4 occasionally kneel, crouch, and crawl; and must avoid concentrated exposure to extreme temperatures, fumes, dust, 5 pulmonary irritants, unprotected heights, and heavy machinery. The claimant can understand, remember, and 6 perform simple work; needs a five minute break every two hours; and can tolerate occasional changes in the workplace. 7 AR 23. With that assessment, the ALJ found Plaintiff unable to perform any past relevant 8 work. AR 30. At step five, the ALJ found Plaintiff capable of making a successful 9 adjustment to other work that exists in significant numbers in the national economy. AR 10 31. The ALJ thus concluded Plaintiff has not been disabled since the alleged onset date. 11 AR 31. 12 IV. DISCUSSION 13 Plaintiff raises the following issues on appeal: (1) Whether the ALJ erred by failing 14 to ensure Plaintiff, who was unrepresented at the hearing, had a fair hearing and erred in 15 failing to adequately develop the record; (2) whether the ALJ properly evaluated the 16 opinion of Plaintiff’s treating physician; and (3) whether the ALJ properly concluded 17 Plaintiff would be capable of performing light work. Plaintiff requests remand for further 18 administrative proceedings. The Commissioner argues the ALJ’s decision has the support 19 of substantial evidence and should be affirmed. 20 1. Whether Plaintiff received a full and fair hearing. 21 Plaintiff argues the ALJ failed to ensure Plaintiff received a full and fair hearing 22 because Plaintiff, who has limited English proficiency, had difficulty communicating at the 23 hearing and experienced challenges with the use of an interpreter. Dkt. 11, at 3–10. “The 1 ALJ has a duty to conduct a full and fair hearing . . . and must be ‘especially diligent’ when 2 the claimant is unrepresented . . . .” McLeod v. Astrue, 640 F.3d 881, 885 (9th Cir. 2011) 3 (citation omitted). The ALJ further has a “duty to ‘conduct an appropriate inquiry’” where

4 the evidence is ambiguous or the ALJ finds “the record is inadequate to allow for proper 5 evaluation of the evidence.” Tonapetyan v. Halter, 242 F.3d 1144, 1150 (9th Cir. 2001) 6 (citation omitted). “A specific finding of ambiguity or inadequacy of the record is not 7 necessary to trigger this duty to inquire, where the record establishes ambiguity or 8 inadequacy.” McLeod, 640 F.3d at 885. 9 Here, the record is inadequate and ambiguous as to whether Plaintiff waived her 10 right to counsel at the hearing. When the ALJ first asked Plaintiff at the hearing whether 11 she gave up her right to have a representative, Plaintiff responded “No” and asked if her 12 brother-in-law could help her. AR 38–39. Even after a Vietnamese interpreter joined the 13 hearing, Plaintiff appeared to deny waiving her right to a representative:

14 ALJ: [to Plaintiff] – did you tell me do you want to give up your right to a representative? 15 CLMT: No, don’t. 16 AR 41–42. The hearing transcript thus indicates Plaintiff denied waiving her right to 17 representation at least twice during the hearing. Additionally, although Plaintiff asserted 18 she did not want to postpone the hearing, Plaintiff’s response does not clearly indicate 19 Plaintiff waived her right to a representative: 20 ALJ: [to Plaintiff] Do you want to give up your right to a 21 representative and proceed here today or do you want to ask me for a postponement to get a representative? 22 CLMT: I would like to proceed here today. 23 1 AR 42. The ambiguity in Plaintiff’s response is even more apparent given the difficulties 2 Plaintiff had with understanding and communicating through the interpreter, as discussed 3 below. Therefore, the record is ambiguous and does not adequately show Plaintiff waived

4 her right to a representative at the hearing. 5 Additionally, the hearing transcript indicates Plaintiff had difficulty communicating 6 through the interpreter.

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Related

McLeod v. Astrue
640 F.3d 881 (Ninth Circuit, 2011)
Clark v. Astrue
529 F.3d 1211 (Ninth Circuit, 2008)
Leslie Woods v. Kilolo Kijakazi
32 F.4th 785 (Ninth Circuit, 2022)

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