Meiss v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedSeptember 9, 2025
Docket3:24-cv-08156
StatusUnknown

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

Bluebook
Meiss v. Commissioner of Social Security Administration, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Nichole Meiss, No. CV-24-08156-PCT-MTL

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 At issue is the denial by the Social Security Administration of Plaintiff Nichole 16 Meiss’ second application for Title XVI Supplemental Security Income (“SSI”) benefits 17 under the Social Security Act. Meiss filed a complaint and an opening brief with the Court 18 seeking judicial review of that denial. (Docs. 1, 19.) Defendant Commissioner of the Social 19 Security Administration (“Commissioner”) submitted a response brief (Doc. 21), and 20 Meiss submitted a reply (Doc. 22). The Court has reviewed the briefs and the 21 administrative record (“A.R.”) (Docs. 13, 14) and now affirms the Administrative Law 22 Judge’s (“ALJ”) decision. 23 I. BACKGROUND 24 A. Procedural History 25 As relevant here, Meiss applied for SSI benefits on September 27, 2021,1 for a 26 period of disability beginning on March 2, 2021.2 (A.R. at 210.) Meiss’ claim was initially

27 1 The application shows a date of September 27, 2021; however, the ALJ’s decision and the parties’ briefs list September 14, 2021, as the application date. (A.R. at 210; Doc. 19 at 28 2; Doc. 21 at 1.) This discrepancy does not affect the Court’s analysis. 2 This is Meiss’ second application for SSI benefits. Her first application was denied on 1 denied on May 31, 2022 (id. at 114), and upon reconsideration on February 17, 2023 (id. 2 at 122). Meiss thereafter filed a request for a hearing which was held telephonically before 3 the ALJ on November 30, 2023. (Id. at 34-56.) On January 22, 2024, the ALJ issued an 4 unfavorable decision, denying her claim. (Id. at 12-33.) Meiss subsequently filed a request 5 for review with the Appeals Council, which was denied on July 9, 2024. (Id. at 1-6.) Meiss 6 now seeks judicial review with this Court pursuant to 42 U.S.C. § 405(g). (Doc. 1 at 1-2.) 7 B. ALJ Determination 8 The Court has reviewed the record and will discuss the pertinent evidence in 9 addressing the issues raised by the parties. After considering the medical evidence and 10 opinions, the ALJ evaluated Meiss’ disability claim based on the following severe 11 impairments: (1) degenerative disc disease; (2) migraine headaches; (3) Gastroesophageal 12 reflux disease (“GERD”); (4) obesity; (5) depression; and (6) anxiety. (A.R. at 18.) 13 The ALJ found that Meiss “d[id] not have an impairment or combination of 14 impairments that meets or medically equals the severity of one of the listed impairments in 15 20 C.F.R. Part 404, Subpart P, Appendix 1.” (Id. at 18.) Next, the ALJ determined Meiss’ 16 residual functional capacity (“RFC”).3 The ALJ found: 17 [T]he claimant has the residual functional capacity to perform light work as defined in 20 CFR 416.967(b) except she can sit 18 6 hours out of an 8-hour day; stand 6 hours out of 8-hour day; walk 6 hours out of an 8-hour day; occasionally lift and carry 19 20 pounds and frequently lift and carry 10 pounds; occasionally climb, stoop, kneel, crouch, and crawl; and have 20 only occasional exposure to heights, moving machinery, temperature extremes, and vibrations. She can understand, 21 remember and carry out simple job instructions only, with only occasional interaction with co-workers, the public, and 22 supervisors. Occasional is defined as very little to 1/3 of the time. Frequent is defined as 1/3 to 2/3 of the time. 23 24 (Id. at 20.) Based on this RFC and the testimony of vocational expert Robin Scher, the ALJ 25 February 8, 2020. (A.R. at 17, 60-73.) Meiss was therefore presumed not disabled in her 26 current application pursuant to Social Security Acquiescence Ruling 97-4(9), and the ALJ found that she had not established changed circumstances indicating a greater disability to 27 rebut that presumption. (Id. at 18.) The ALJ nonetheless evaluated the medical evidence and denied her application on the merits. (Id.) 28 3 Residual functional capacity refers to the most a claimant can still do in a work setting despite his or her limitations. 20 C.F.R. § 416.945(a)(1). 1 found that Meiss could perform jobs that existed in significant numbers in the national 2 economy. (Id. at 28, 51-55, 181.) Thus, the ALJ concluded that Meiss was not disabled 3 from the time of her application according to § 1614(a)(3)(A) of the Social Security Act. 4 (Id. at 29.) 5 II. LEGAL STANDARD 6 The district court reviews only those issues raised by the party challenging the ALJ’s 7 decision. See Lewis v. Apfel, 236 F.3d 503, 517 n.13 (9th Cir. 2001). The Court may set 8 aside the ALJ’s determination only if it is not supported by substantial evidence or if it is 9 based on legal error. Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007). Substantial evidence 10 is relevant evidence that a reasonable person might accept as adequate to support a 11 conclusion considering the entire record. Id. To determine whether substantial evidence 12 supports a decision, the Court must consider the entire record and may not affirm simply 13 by isolating a “specific quantum of supporting evidence.” Id. (citation omitted). Generally, 14 “[w]here the evidence is susceptible to more than one rational interpretation, one of which 15 supports the ALJ’s decision, the ALJ’s conclusion must be upheld.” Thomas v. Barnhart, 16 278 F.3d 947, 954 (9th Cir. 2002). The substantial evidence threshold “defers to the 17 presiding ALJ, who has seen the hearing up close.” Biestek v. Berryhill, 587 U.S. 97, 108 18 (2019); see also Thomas v. CalPortland Co., 993 F.3d 1204, 1208 (9th Cir. 2021) (noting 19 substantial evidence “is an extremely deferential standard”). 20 To determine whether a claimant is disabled, the ALJ follows a five-step process. 21 See 20 C.F.R. § 416.920(a)(4). The claimant bears the burden of proof on the first four 22 steps, but the burden shifts to the Commissioner at step five. Tackett v. Apfel, 180 F.3d 23 1094, 1098 (9th Cir. 1999). At the first step, the ALJ determines whether the claimant is 24 presently engaging in substantial gainful activity. 20 C.F.R. § 416.920(a)(4)(i), (b). If so, 25 the claimant is not disabled, and the inquiry ends. Id. If the claimant is not working in a 26 substantially gainful activity, then the claimant’s case proceeds to step two. Id. At step two, 27 the ALJ determines whether the claimant has a “severe” medically determinable physical 28 or mental impairment. Id. § 416.920(a)(4)(ii), (c). If not, the claimant is not disabled, and 1 the inquiry ends. Id. If the claimant’s impairment is severe, then the inquiry proceeds to 2 step three. See id. At step three, the ALJ considers whether the claimant’s impairment or 3 combination of impairments meets or medically equals an impairment listed in Appendix 1 4 to Subpart P of Part 404. Id. § 416.920(a)(4)(iii). If so, the claimant is automatically found 5 to be disabled. Id.

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Meiss v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meiss-v-commissioner-of-social-security-administration-azd-2025.