Marcotte v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedJuly 7, 2023
Docket3:22-cv-05881
StatusUnknown

This text of Marcotte v. Commissioner of Social Security (Marcotte 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
Marcotte 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 EMILY ANN M., CASE NO. 3:22-CV-5881-DWC 11 Plaintiff, ORDER AFFIRMING DEFENDANT’S 12 v. DECISION DENYING BENEFITS 13 COMMISSIONER OF SOCIAL SECURITY, 14 Defendant. 15

Plaintiff filed this action, pursuant to 42 U.S.C. § 405(g), for judicial review of the denial 16 of his applications for social security insurance (SSI) benefits. Pursuant to 28 U.S.C. § 636(c), 17 Fed. R. Civ. P. 73 and Local Rule MJR 13 the parties have consented to proceed before the 18 undersigned. After considering the record the Court finds no reversable error and affirms the 19 Commissioner’s decision to deny benefits. 20 21 I. BACKGROUND 22 Plaintiff filed an application for SSI on December 17, 2019 alleging disability beginning 23 July 31, 2017. Administrative Record (AR) 15. Her application was denied initially and upon 24 reconsideration. Id. After Plaintiff filed a request for a hearing, a telephonic hearing was held 1 before an administrative law judge (ALJ) on June 21, 2021 at which Plaintiff was represented 2 and testified. Id. On July 28, 2021 the ALJ issued a written decision denying Plaintiff’s claim. 3 AR 13-43. The Appeals Council then denied Plaintiff’s request for review, making the ALJ’s 4 decision final. AR 2.

5 II. THE ALJ’S FINDINGS 6 The ALJ found Plaintiff has the severe impairments of disorders of the spine, including 7 degenerative disc disease of the thoracic and lumbar spine; osteoarthritis; migraines; obesity; 8 anxiety; depression; and trauma-related disorders (20 CFR § 416.920(c)). AR 19. 9 The ALJ found the combination of Plaintiff’s impairments do not meet or equal any 10 Listed Impairment. AR 20. 11 The ALJ determined that Plaintiff has the residual functional capacity (RFC) to perform 12 light work as defined in 20 CFR § 416.967(b) except: 13 never climbing ladders, ropes, or scaffolds; frequent stooping; no exposure to high concentrations of smoke, fumes, pollutants, and dust; never have exposure to 14 dangerous machinery and unprotected heights; can do no complex tasks but can do simple (routine) tasks which I define to mean this person has the basic mental 15 aptitude to meet the demands of competitive, remunerative, unskilled work include the abilities to, on a sustained basis, understand, carry out, and remember simple 16 instructions; can respond appropriately to supervision, coworkers, and usual work situations; can deal with changes in routine work settings; can focus attention on 17 simple or routine work activities for at least 2 hours at a time and can stay on task at a sustained rate such as initiating and performing a task that they understand and 18 know how to do; can work at an appropriate and consistent pace and can complete tasks in a timely manner; can ignore or avoid distractions while working; can 19 change activities or work settings without being disruptive; can do only low stress work meaning no high production quotas or piece rate work; can do no tasks 20 requiring tandem or a team effort; and can have occasional and superficial interactions with public and co-workers, with “superficial” meaning limited to 21 speaking, signaling, taking instructions, asking questions and similar contact, but with no arbitration, negotiation, confrontation, or supervising others, and no 22 commercial driving.

23 AR 28. 24 1 The ALJ found that a person of Plaintiff’s age, with her education, work experience, and 2 RFC, could perform jobs existing in significant numbers in the national economy such as 3 Housekeeping Cleaner, Merchandise Marker, and Photocopy Machine Operator. AR 42. 4 III. STANDARD

5 Pursuant to 42 U.S.C. § 405(g) this Court may set aside the Commissioner’s denial of 6 social security benefits if the ALJ’s findings are based on legal error or not supported by 7 substantial evidence in the record as a whole. Bayliss v. Barnhart, 427 F.3d 1211, 1214 n.1 (9th 8 Cir. 2005) (citing Tidwell v. Apfel, 161 F.3d 599, 601 (9th Cir. 1999)). However, the 9 Commissioner’s decision must be affirmed if it is supported by substantial evidence and free of 10 harmful legal error. 42 U.S.C. § 405(g); Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 11 2008). 12 Substantial evidence “is a highly deferential standard of review.” Valentine v. Comm’r of 13 Soc. Sec. Admin., 574 F.3d 685, 690 (9th Cir. 2009). The Supreme Court describes it as “more 14 than a mere scintilla.” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019). “It means—and means

15 only—such relevant evidence as a reasonable mind might accept as adequate to support a 16 conclusion.” Id. (internal quotations omitted). 17 IV. DISCUSSION 18 A. Reopening Request 19 At the hearing before the ALJ, Plaintiff’s counsel asked to reopen Plaintiff’s prior SSI 20 claim, which had been decided by another ALJ and denied on June 19, 2018. AR 16. The ALJ 21 declined to do so, explaining that Plaintiff’s counsel’s contention that Plaintiff did not have the 22 mental capacity to represent herself effectively at the prior hearing was not supported by any 23 evidence. Id. The ALJ noted that the record before the ALJ showed Plaintiff’s mental exams 24 1 were “generally unremarkable”, her memory was intact, her mood and affect were appropriate, 2 and her judgment was normal. Id. The ALJ noted the only “remarkable finding” in the mental 3 health evidence was that one of the state-agency consultative examiners found Plaintiff’s test 4 results were “indicative of malingering”. Id. Further, the ALJ stated the record does not support

5 Plaintiff’s counsel’s claim that Plaintiff has “mental deficiencies” or is “limited to the exten[t] 6 she is unable to understand the consequences of her actions and unable to make a valid informed 7 choice/consent at her prior hearing.” Id. The ALJ also noted that Plaintiff’s counsel had not 8 pointed to any evidence to support reopening. Id. 9 In addition, because Plaintiff’s alleged disability onset date of July 31, 2017 in the newly 10 filed case “falls within the previously adjudicated period” to which “the doctrine of res judicata 11 applies”, the ALJ amended Plaintiff’s alleged onset of disability to June 20, 2018. Id. 12 Plaintiff argues the ALJ erred by failing to properly consider her request to reopen the 13 prior hearing. According to Plaintiff, she was not “adequately advised of her right to obtain a 14 representative at the prior hearing” and she did not understand the procedures for requesting

15 review because she suffers from mental conditions that limit her “ability to do things for herself.” 16 Dkt. 16 at 5-6.

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