Mercado v. Kijakazi

CourtDistrict Court, S.D. California
DecidedMarch 2, 2023
Docket3:22-cv-01713
StatusUnknown

This text of Mercado v. Kijakazi (Mercado v. Kijakazi) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mercado v. Kijakazi, (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JUAN CARLOS MERCADO, Case No.: 22-CV-1713 (NLS)

12 Plaintiff, (1) ORDER DISMISSING 13 v. COMPLAINT WITH LEAVE TO AMEND; 14 KILOLO KIJAKAZI, Acting

Commissioner of Social Security 15 (2) ORDER DENYING MOTION Administration, FOR APPOINTMENT OF 16 Defendant. COUNSEL; and 17 (3) ORDER DENYING MOTION 18 FOR IFP 19 [ECF Nos. 2, 3] 20

21 Juan Carlos Mercado (“Plaintiff”), proceeding pro se, seeks review of a decision 22 by the Social Security Commissioner that denied his application for benefits. ECF No. 1. 23 The parties have consented to Magistrate Judge jurisdiction over the case. ECF No. 5. 24 Before the Court is Plaintiff’s complaint seeking review of the Social Security 25 Administration’s decision, motion to proceed in forma pauperis (IFP), and motion for 26 appointment of counsel to represent him in this action. ECF Nos. 1-3. For the following 27 reasons, the Court DISMISSES the complaint with leave to amend, if amended within 60 28 1 days of this order, DENIES the motion to proceed IFP, and DENIES without prejudice 2 the motion for appointment of counsel. 3 I. Screening Under 28 U.S.C. § 1915(e) 4 A complaint filed pursuant to the IFP provisions of 28 U.S.C. § 1915(a), is subject 5 to a mandatory and sua sponte review by the Court. Lopez v. Smith, 203 F.3d 1122, 1127 6 (9th Cir. 2000). The Court must dismiss the complaint if it is frivolous or malicious, fails 7 to state a claim upon which relief may be granted, or seeks monetary relief from a 8 defendant immune from such relief. 28 U.S.C. § 1915(e)(2)(B). Social security appeals 9 are not exempt from this § 1915(e) screening requirement. Hoagland v. Astrue, No. 10 1:12cv00973-SMS, 2012 WL 2521753, at *1 (E.D. Cal. June 28, 2012); see also Calhoun 11 v. Stahl, 254 F.3d 845, 845 (9th Cir. 2001) (per curiam) (noting section 1915(e)(2)(B) is 12 “not limited to prisoners”); Lopez, 203 F.3d at 1129 (“section 1915(e) applies to all in 13 forma pauperis complaints”). 14 To pass screening, all complaints must contain a “short and plain statement of the 15 claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Although 16 detailed factual allegations are not required, “[t]hreadbare recitals of the elements of a 17 cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. 18 Iqbal, 556 U.S. 662, 678 (2009). A complaint in a social security appeal is “not exempt 19 from the general rules of civil pleading.” Hoagland, 2012 WL 2521753, at *2. 20 Several courts within the Ninth Circuit have set forth the following basic 21 requirements for complaints to survive the Court’s § 1915(e) screening: 22 First, the plaintiff must establish that she has exhausted her administrative remedies pursuant to 42 U.S.C. § 405(g), and that the civil action was 23 commenced within sixty days after notice of a final decision. Second, the 24 complaint must indicate the judicial district in which the plaintiff resides. Third, the complaint must state the nature of the plaintiff's disability and 25 when the plaintiff claims she became disabled. Fourth, the complaint must 26 contain a plain, short, and concise statement identifying the nature of the plaintiff's disagreement with the determination made by the Social Security 27 Administration and show that the plaintiff is entitled to relief. 28 1 See, e.g., Montoya v. Colvin, No. 16cv00454-RFB-NJK, 2016 WL 890922, at *2 (D. 2 Nev. Mar. 8, 2016) (collecting cases); Graves v. Colvin, No. 15cv106-RFB-NJK, 2015 3 WL 357121, *2 (D. Nev. Jan. 26, 2015) (same). 4 As for the fourth requirement, “[e]very plaintiff appealing an adverse decision of 5 the Commissioner believes that the Commissioner was wrong.” Hoagland, 2012 WL 6 2521753, at *3. Thus, a complaint merely stating that the Commissioner's decision was 7 wrong or that “merely parrots the standards used in reversing or remanding a case” is 8 insufficient to satisfy a plaintiff’s pleading requirement. See, e.g., Cribbet v. Comm’r 9 of Social Security, No. 12cv1142-BAM 2012 WL 5308044, *3 (E.D. Cal. Oct. 29, 2012); 10 Graves, 2015 WL 357121, at *2. 11 Instead, “[a] complaint appealing the Commissioner’s denial of disability benefits 12 must set forth a brief statement of facts setting forth the reasons why the Commissioner’s 13 decision was wrong.” Hoagland, 2012 WL 2521753, at *2. The plaintiff must provide a 14 statement identifying the basis of the plaintiff’s disagreement with the Social Security 15 Administration’s determination and must make a showing that she is entitled to relief, “in 16 sufficient detail such that the Court can understand the legal and/or factual issues in 17 dispute so that it can meaningfully screen the complaint pursuant to § 1915(e).” Graves, 18 2015 WL 357121, at *2. 19 Plaintiff alleges that during his hearing, the administrative law judge (ALJ) 20 “repeatedly said he would grant [his] claim due to age and stipulations.” ECF No. 1 at 2. 21 As for relief, Plaintiff states that he asks “to listen to the court recording of the trial.” Id. 22 at 3. However, Plaintiff has failed to articulate any substantive reason indicating the ALJ 23 erred in denying the claim. To survive screening, Plaintiff must be able to allege how the 24 Social Security Administration erred in its decision and why he is entitled to relief. Even 25 accepting the allegations as true, that the ALJ stated the claim would be granted, Plaintiff 26 fails to explain how those statements would arise to legal error or entitle him to relief. 27 Because Plaintiff’s fails to state a claim, the Court must DISMISS the complaint. 28 However, Plaintiff shall have 60 days to amend the deficiencies in the complaint. 1 Plaintiff must provide substantive reasons why the ALJ should have granted his request 2 for benefits based on his actual disabilities. 3 II. Motion to Proceed in forma pauperis 4 An applicant need not be completely destitute to proceed IFP, but he must 5 adequately prove his indigence. Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 6 339–40 (1948). An adequate affidavit should “allege[ ] that the affiant cannot pay the 7 court costs and still afford the necessities of life.” Escobedo v. Applebees, 787 F.3d 1226, 8 1234 (9th Cir. 2015) (citing Adkins, 335 U.S. at 339). No exact formula is “set forth by 9 statute, regulation, or case law to determine when someone is poor enough to earn IFP 10 status.” Escobedo, 787 F.3d at 1235. 11 Consequently, courts must evaluate IFP requests on a case-by-case basis. See id. at 12 1235–36 (declining to implement a general benchmark of “twenty percent of monthly 13 household income”); see also Cal. Men's Colony v. Rowland, 939 F.2d 854, 858 (9th Cir.

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Bluebook (online)
Mercado v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mercado-v-kijakazi-casd-2023.