Marcia Elaine Loughney v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedFebruary 19, 2026
Docket2:25-cv-00454
StatusUnknown

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

Bluebook
Marcia Elaine Loughney v. Commissioner of Social Security, (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 MARCIA ELAINE LOUGHNEY, Case No. 2:25-cv-00454-WBS-CSK 12 Plaintiff, FINDINGS AND RECOMMENDATIONS ON PARTIES’ CROSS MOTIONS FOR 13 v. SUMMARY JUDGMENT 14 COMMISSIONER OF SOCIAL (ECF Nos. 6, 9) SECURITY, 15 Defendant. 16 17 Plaintiff Marcia Elaine Loughney seeks judicial review of a final decision by 18 Defendant Commissioner of Social Security denying an application for disability 19 insurance benefits and supplemental security income.1 In her summary judgment 20 motion, Plaintiff contends the final decision of the Commissioner contains legal error and 21 is not supported by substantial evidence. Plaintiff seeks a remand for further 22 proceedings. The Commissioner opposes Plaintiff’s motion, filed a cross-motion for 23 summary judgment, and seeks affirmance. 24 For the reasons below, the Court recommends that Plaintiff’s motion be DENIED, 25 the Commissioner’s cross-motion be GRANTED, and the final decision of the 26 Commissioner be AFFIRMED. 27 1 This action was referred to the magistrate judge under Local Rule 302(c)(15) for the 28 issuance of findings and recommendations. See Local Rule 304. 1 I. SOCIAL SECURITY CASES: FRAMEWORK & FIVE-STEP ANALYSIS 2 The Social Security Act provides benefits for qualifying individuals unable to 3 “engage in any substantial gainful activity by reason of any medically determinable 4 physical or mental impairment[.]” 42 U.S.C. § 423(d)(1)(a). When an individual (the 5 “claimant”) seeks Social Security disability benefits, the process for administratively 6 reviewing the request can consist of several stages, including: (1) an initial determination 7 by the Social Security Administration; (2) reconsideration; (3) a hearing before an 8 Administrative Law Judge (“ALJ”); and (4) review of the ALJ’s determination by the 9 Social Security Appeals Council. 20 C.F.R. § 404.900(a). 10 At the hearing stage, the ALJ is to hear testimony from the claimant and other 11 witnesses, accept into evidence relevant documents, and issue a written decision based 12 on a preponderance of the evidence in the record. 20 C.F.R. § 416.1429. In evaluating a 13 claimant’s eligibility, the ALJ is to apply the following five-step analysis:

14 Step One: Is the claimant engaged in substantial gainful activity? If yes, the claimant is not disabled. If no, proceed to step two. 15 Step Two: Does the claimant have a “severe” impairment? If no, the claimant is not disabled. If yes, proceed to step three. 16

Step Three: Does the claimant’s combination of impairments meet or 17 equal those listed in 20 C.F.R., Pt. 404, Subpt. P, App. 1 (the “Listings”)? If yes, the claimant is disabled. If no, proceed to step four. 18 Step Four: Is the claimant capable of performing past relevant work? If 19 yes, the claimant is not disabled. If no, proceed to step five.

20 Step Five: Does the claimant have the residual functional capacity to perform any other work? If yes, the claimant is not disabled. If no, the 21 claimant is disabled.

22 Lester v. Chater, 81 F.3d 821, 828 n.5 (9th Cir. 1995); 20 C.F.R. § 404.1520(a)(4). The 23 burden of proof rests with the claimant through step four, and with the Commissioner at 24 step five. Ford v. Saul, 950 F.3d 1141, 1148 (9th Cir. 2020). If the ALJ finds a claimant 25 not disabled, and the Social Security Appeals Council declines review, the ALJ's 26 decision becomes the final decision of the Commissioner. Brewes v. Comm'r., 682 F.3d 27 1157, 1161-62 (9th Cir. 2012) (noting the Appeals Council’s denial of review is a non- 28 final agency action). At that point, the claimant may seek judicial review of the 1 Commissioner’s final decision by a federal district court. 42 U.S.C. § 405(g). 2 The district court may enter a judgment affirming, modifying, or reversing the final 3 decision of the Commissioner. Id. (“Sentence Four” of § 405(g)). In seeking judicial 4 review, the plaintiff is responsible for raising points of error, and the Ninth Circuit has 5 repeatedly admonished that the court cannot manufacture arguments for the plaintiff. 6 See Mata v. Colvin, 2014 WL 5472784, at *4 (E.D. Cal, Oct. 28, 2014) (citing Indep. 7 Towers of Wash. v. Washington, 350 F.3d 925, 929 (9th Cir. 2003) (stating that the court 8 should “review only issues which are argued specifically and distinctly,” and noting a 9 party who fails to raise and explain a claim of error waives it). 10 A district court may reverse the Commissioner’s denial of benefits only if the ALJ’s 11 decision contains legal error or is unsupported by substantial evidence. Ford, 950 F.3d. 12 at 1154. Substantial evidence is “more than a mere scintilla” but “less than a 13 preponderance,” i.e., “such relevant evidence as a reasonable mind might accept as 14 adequate to support a conclusion.” Id. (citations omitted). The court reviews evidence in 15 the record that both supports and detracts from the ALJ’s conclusion, but may not affirm 16 on a ground upon which the ALJ did not rely. Luther v. Berryhill, 891 F.3d 872, 875 (9th 17 Cir. 2018). The ALJ is responsible for resolving issues of credibility, conflicts in 18 testimony, and ambiguities in the record. Ford, 950 F.3d at 1154. The ALJ’s decision 19 must be upheld where the evidence is susceptible to more than one rational 20 interpretation, or where any error is harmless. Id. 21 II. FACTUAL BACKGROUND AND ALJ’S FIVE-STEP ANALYSIS 22 On February 17, 2022, Plaintiff applied for a period of disability and disability 23 insurance benefits under Title II of the Social Security Act, alleging she has been 24 disabled since July 19, 2021. Administrative Transcript (“AT”) at 58 (available at ECF No. 25 5). Plaintiff claimed disability due to a fusion in the back at L4 and L52, a fused right 26 27 2 The L4 and L5 are two of five bones that exist on the lower back region of the spinal 28 column. 1 sacroiliac (“SI”) joint3, a fused left SI joint, severe arthritis, bulging discs in back, spinal 2 stenosis in back, synovial cyst on the spine, and sinus tachycardia. Id. Plaintiff’s 3 applications were denied initially and upon reconsideration; she sought review before an 4 ALJ. Id. at 70, 72, 104, 111. Plaintiff appeared with a representative at a May 4, 2024 5 hearing before an ALJ, where Plaintiff testified about her impairments and a vocational 6 expert testified about hypothetical available jobs in the national economy. Id. at 23-49. 7 On December 11, 2024, the ALJ issued a decision finding Plaintiff was not 8 disabled. Id. at 1-22. At step one, the ALJ found Plaintiff had not engaged in substantial 9 gainful activity since July 19, 2021. Id. at 12. At step two, the ALJ determined Plaintiff 10 had the following severe impairments: lumbar spine dysfunction and bilateral sacroiliac 11 dysfunctions status post fusions. Id. At step three, the ALJ found Plaintiff’s combination 12 of impairments did not meet or medically equal any Listing. Id. at 13. (citing 20 C.F.R 13 Part 404, Subpart P, Appendix 1).

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Bluebook (online)
Marcia Elaine Loughney v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marcia-elaine-loughney-v-commissioner-of-social-security-caed-2026.