Maura v. Colvin

CourtDistrict Court, E.D. Washington
DecidedJanuary 10, 2025
Docket4:24-cv-05105
StatusUnknown

This text of Maura v. Colvin (Maura v. Colvin) 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
Maura v. Colvin, (E.D. Wash. 2025).

Opinion

1 FILED IN THE U.S. DISTRICT COURT 2 EASTERN DISTRICT OF WASHINGTON Jan 10, 2025 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 BRITTANY M., NO. 4:24-CV-5105-TOR 8 Plaintiff, ORDER AFFIRMING 9 v. COMMISSIONER’S DENIAL OF BENEFITS UNDER TITLES II & XVI 10 CAROLYN COLVIN, Acting OF THE SOCIAL SECURITY ACT Commissioner of Social Security 1 11 Defendant. 12

13 BEFORE THE COURT is Plaintiff’s Motion for judicial review of 14 Defendant’s denial of her application for Title II and Title XVI under the Social 15

1 Carolyn Colvin became the Acting Commissioner of Social Security on 16 November 30, 2024. Pursuant to Rule 25(d) of the Federal Rules of Civil 17 Procedure, Carolyn Colvin is substituted for Martin O’Malley as the defendant in 18 this suit. No further action need be taken to continue this under the Social Security 19 Act, 42 U.S.C. § 405(g). 20 1 Security Act (ECF No. 7). This matter was submitted for consideration without 2 oral argument. The Court has reviewed the administrative record and is fully

3 informed. For the reasons discussed below, the Commissioner’s denial of 4 Plaintiff’s application for benefits under Title II and Title XVI of the Social 5 Security Act is AFFIRMED.

6 JURISDICTION 7 The Court has jurisdiction under 42 U.S.C. §§ 405(g), 1383(c)(3). 8 STANDARD OF REVIEW 9 A district court’s review of a final decision of the Commissioner of Social

10 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 11 limited: the Commissioner’s decision will be disturbed “only if it is not supported 12 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153,

13 1158-59 (9th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence” means 14 relevant evidence that “a reasonable mind might accept as adequate to support a 15 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, 16 substantial evidence equates to “more than a mere scintilla[,] but less than a

17 preponderance.” Id. (quotation and citation omitted). In determining whether this 18 standard has been satisfied, a reviewing court must consider the entire record as a 19 whole rather than searching for supporting evidence in isolation. Id.

20 1 In reviewing a denial of benefits, a district court may not substitute its 2 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152,

3 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 4 rational interpretation, [the court] must uphold the ALJ’s findings if they are 5 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674

6 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an 7 ALJ’s decision on account of an error that is harmless.” Id. An error is harmless 8 “where it is inconsequential to the [ALJ’s] ultimate nondisability determination.” 9 Id. at 1115 (quotation and citation omitted). The party appealing the ALJ’s

10 decision generally bears the burden of establishing that it was harmed. Shinseki v. 11 Sanders, 556 U.S. 396, 409-10 (2009). 12 FIVE STEP SEQUENTIAL EVALUATION PROCESS

13 A claimant must satisfy two conditions to be considered “disabled” within 14 the meaning of the Social Security Act. First, the claimant must be “unable to 15 engage in any substantial gainful activity by reason of any medically determinable 16 physical or mental impairment which can be expected to result in death or which

17 has lasted or can be expected to last for a continuous period of not less than twelve 18 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). Second, the claimant’s 19 impairment must be “of such severity that [he or she] is not only unable to do [his

20 or her] previous work[,] but cannot, considering [his or her] age, education, and 1 work experience, engage in any other kind of substantial gainful work which exists 2 in the national economy.” 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B).

3 The Commissioner has established a five-step sequential analysis to 4 determine whether a claimant satisfies the above criteria. See 20 C.F.R. §§ 5 404.152(a)(4)(i)-(v), 416.920(a)(4)(i)-(v). At step one, the Commissioner

6 considers the claimant’s work activity. 20 C.F.R. §§ 404.1520(a0(4)(i), 7 416.920(a)(4)(i). If the claimant is engaged in “substantial gainful activity,” the 8 Commissioner must find that the claimant is not disabled. 20 C.F.R. §§ 9 404.1520(b), 416.920(b). Substantial work activity is “activity that involves doing

10 significant physical or mental activities,” even if performed on a part -time basis. 11 20 C.F.R. § 404.1572(a). “Gainful work activity” is work performed “for pay or 12 profit,” or “the kind of work usually done for pay or profit, whether or not a profit

13 is realized.” 20 C.F.R. § 404.1572(b). 14 If the claimant is not engaged in substantial gainful activities, 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. §§ 416.1520(a)(4)(ii), 416.920(a)(4)(ii). If the

17 claimant suffers from “any impairment or combination of impairments which 18 significantly limits [his or her] physical or mental ability to do basic work 19 activities,” the analysis proceeds to step three. 20 C.F.R. §§ 404.1520(c),

20 1 416.920(c). If the claimant’s impairment does not satisfy this severity threshold, 2 however, the Commissioner must find that the claimant is not disabled. Id.

3 At step three, the Commissioner compares the claimant’s impairment to 4 several impairments recognized by the Commissioner to be so severe as to 5 preclude a person from engaging in substantial gainful activity. 20 C.F.R. §

6 416.920(a)(4)(iii). If the impairment is as severe or more severe than one of 7 enumerated impairments, the Commissioner must find the claimant disabled and 8 award benefits. 20 C.F.R. § 416.920(d). 9 If the severity of the claimant’s impairment does meet or exceed the severity

10 of the enumerated impairments, the Commissioner must pause to assess the 11 claimant’s “residual functional capacity” (“RFC”) before awarding benefits.

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