Lussier v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJune 2, 2025
Docket3:24-cv-05492
StatusUnknown

This text of Lussier v. Commissioner of Social Security (Lussier 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
Lussier v. Commissioner of Social Security, (W.D. Wash. 2025).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 JOANN L. LUSSIER, 9 Plaintiff, Case No. C24-5492-SKV 10 v. OPINION AND ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13

14 On June 24, 2024, Plaintiff Joann L. Lussier (“Plaintiff”) sued the Commissioner of 15 Social Security and Social Security Administration (collectively “Defendant”). See Dkt. 4. 16 Plaintiff alleges she has been disabled since at least April 15, 2021, and claims Defendant 17 wrongfully denied her Social Security Disability Insurance (“SSDI”) application. See Dkt. 4 at 18 2. Plaintiff seeks an order reversing the Administrative Law Judge’s (“ALJ”) adverse decision 19 and awarding benefits accrued since April 2021. See Dkt. 4 at 3. 20 Before the Court is Defendant’s motion to dismiss this case pursuant to Federal Rules of 21 Civil Procedure 12(b)(1) and 12(h)(3).1 See Dkt. 21 at 1. Defendant argues Plaintiff received 22

23 1 The Court declines Plaintiff’s unsupported invitation to construe the Government’s filing as a responsive brief. See Dkt. 22 at 1. “Because standing and mootness both pertain to a federal court’s subject-matter jurisdiction under 1 benefits for the period at issue on October 2, 2024, through a separate, successful SSDI 2 application, which defeats her standing, moots her claim, and deprives this Court of subject 3 matter jurisdiction. See Dkt. 21 at 2–3; Dkt 21-1 (Notice of Award of SSDI benefits accrued 4 since November 2020). For the following reasons, the Court finds Plaintiff’s claim

5 nonjusticiable and DISMISSES this case without prejudice. 6 I. DISCUSSION 7 The Court reviews the nature of Defendant’s challenge before considering the merits. 8 A. Rule 12(b)(1) 9 Defendants can mount a Rule 12(b)(1) challenge to plaintiffs’ jurisdictional allegations in 10 two ways. “A ‘facial’ attack accepts the truth of the plaintiff’s allegations but asserts that they 11 ‘are insufficient on their face to invoke federal jurisdiction.’” Leite v. Crane Co., 749 F.3d 1117, 12 1121 (9th Cir. 2014) (quoting Safe Air for Everyone v. Meyer, 373 F.3d 1035, 1039 (9th Cir. 13 2004)). “A ‘factual’ attack, by contrast, contests the truth of the plaintiff’s factual allegations, 14 usually by introducing evidence outside the pleadings.” Id. (first citing Safe Air, 373 F.3d at

15 1039; and then citing Thornhill Publ’g Co. v. Gen. Tel. & Elec. Corp., 594 F.2d 730, 733 (9th 16 Cir. 1979)). “When the defendant raises a factual attack, the plaintiff must support her 17 jurisdictional allegations with ‘competent proof,’ under the same . . . [preponderance of the 18 evidence] standard that governs in the summary judgment context.” Id. (citations omitted). 19 District courts may resolve factual disputes necessary for a jurisdictional inquiry at the motion to 20 dismiss stage. Id. at 1121–22 (first citing Safe Air, 373 F.3d at 1039–40; then citing Augustine v. 21 United States, 704 F.2d 1074, 1077 (9th Cir. 1983); and then citing Thornhill, 594 F.2d at 733). 22

Article III, they are properly raised in a motion to dismiss under Federal Rule of Civil Procedure 12(b)(1).” White v. 23 Lee, 227 F.3d 1214, 1242 (9th Cir. 2000). Furthermore, the Court must dismiss any action over which it lacks subject matter jurisdiction, regardless of the procedural posture. See Fed. R. Civ. P. 12(h)(3). 1 Here, Defendant mounts a factual challenge contesting the accuracy of Plaintiff’s core 2 allegation: that she was denied benefits for the period between her alleged onset of disability on 3 April 15, 2021, and the ALJ’s unfavorable decision on September 25, 2023. See Dkt. 21 at 4; 4 Dkt 22 at 2. In support, Defendant offers a Notice of Award, dated October 2, 2024, informing

5 Plaintiff that she is “entitled to monthly disability benefits from Social Security beginning 6 November 2020.” Dkt. 21-1 at 1. Plaintiff received the Notice of Award after filing a separate 7 SSDI application alleging disability since November 2020. See id; Dkt. 26 at 3. 8 Plaintiff offers no evidence to support her jurisdictional allegations or rebut Defendant’s 9 evidence that she has already been awarded the benefits sought in this case. Instead, Plaintiff 10 notes there is no evidence in the record that she received the funds.2 See Dkt. 22 at 3. That is 11 irrelevant. Payment issues fall outside the scope of this Court’s review. See 42 U.S.C. § 405(g). 12 To the extent there is a factual dispute here, the Court finds Plaintiff received a grant of benefits 13 that covers the entire period for which she seeks benefits in this action. See Dkt. 21-1. With the 14 facts straight, the Court reviews their impact on its subject matter jurisdiction.

15 B. Justiciability 16 Article III of the Constitution limits federal courts’ subject matter jurisdiction to cases 17 and controversies. See U.S. Const. art. III. Various justiciability doctrines guide Courts’ 18 analysis of whether they can, and should, decide cases in view of that limited constitutional 19 mandate. Three such doctrines— standing, ripeness, and mootness—apply here. 20 “[T]o satisfy Article III’s standing requirements, a plaintiff must show (1) it has suffered 21 an ‘injury in fact’ that is (a) concrete and particularized and (b) actual or imminent, not 22 conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the 23

2 Plaintiff does not deny receiving the funds, either in full or in part. 1 defendant; and . . . [(3)] it is likely, as opposed to merely speculative, that the injury will be 2 redressed by a favorable decision.” Friends of the Earth, Inc. v. Laidlaw Env’t Servs. (TOC), 3 Inc., 528 U.S. 167, 180–81 (2000) (citing Lujan v. Defenders of Wildlife, 504 U.S. 555, 560–61 4 (1992)).

5 “[A]n actual controversy must be extant at all stages of review, not merely at the time the 6 complaint is filed.” Arizonans for Off. Eng. v. Arizona, 520 U.S. 43, 67 (1997) (quoting Preiser 7 v. Newkirk, 422 U.S. 395, 401 (1975)). That is where mootness and ripeness come in. “While 8 standing is primarily concerned with who is a proper party to litigate a particular matter, ripeness 9 [and mootness] address[] when litigation may occur.” Bova v. City of Medford, 564 F.3d 1093, 10 1096 (9th Cir. 2009) (quoting Lee v. Oregon, 107 F.3d 1382, 1387 (9th Cir. 1997)). As such, 11 both doctrines can be characterized as “standing set in a time frame.” Foster v. Carson, 347 F.3d 12 742, 745 (9th Cir. 2003); see Thomas v. Anchorage Equal Rts. Comm’n, 220 F.3d 1134, 1138 13 (9th Cir. 2000) (en banc). The timely asserted (ripe), “personal interest that must exist at the 14 commencement of the litigation (standing) must continue throughout its existence (mootness).”

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Lussier v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lussier-v-commissioner-of-social-security-wawd-2025.