Mourning, Jr. v. Kijakazi

CourtDistrict Court, N.D. California
DecidedAugust 26, 2024
Docket3:23-cv-03382
StatusUnknown

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

Bluebook
Mourning, Jr. v. Kijakazi, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 R.M., Case No. 23-cv-03382-LJC

8 Plaintiff, ORDER REGARDING CROSS- 9 v. MOTIONS FOR SUMMARY JUDGMENT 10 MARTIN O’MALLEY, Re: Dkt. Nos. 10, 12 Defendant. 11

12 I. INTRODUCTION 13 Plaintiff R.M.1 challenges the final decision of Defendant Martin O’Malley, Commissioner 14 of Social Security (the Commissioner),2 finding R.M. not disabled and thus ineligible for 15 Supplemental Security Income benefits. The parties filed cross-motions for summary judgment 16 under Civil Local Rule 16-5. Although that rule no longer applies to cases that are governed by 17 the Federal Rules of Civil Procedure’s Supplemental Rules for Social Security Actions Under 42 18 U.S.C. § 405(g), the parties’ cross-motions present the issues in a manner substantively consistent 19 with the Supplemental Rules, and the Court proceeds to resolve them. For the reasons discussed 20 below, R.M.’s Motion is GRANTED (except as to the specific relief requested), the 21 Commissioner’s Cross-Motion is DENIED, and the matter is REMANDED to the Commissioner 22 for further administrative proceedings consistent with the Order.3 23 1 Because opinions by the Court are more widely available than other filings, and this Order 24 contains potentially sensitive medical information, this Order refers to the plaintiff only by his initials. This Order does not alter the degree of public access to other filings in this action 25 provided by Rule 5.2(c) of the Federal Rules of Civil Procedure and Civil Local Rule 5-1(c)(5)(B)(i). 26 2 Martin O’Malley was sworn in as Commissioner of Social Security on December 20, 2023, and is therefore automatically substituted as the defendant in this case under Rule 25(d) of the Federal 27 Rules of Civil Procedure. 1 II. BACKGROUND 2 A. Overview 3 R.M. completed high school through a G.E.D. program while in jail and did not receive 4 formal vocational training. Administrative Record (AR) (ECF No. 8) at 68–69.4 After he was 5 released, he found a job with a cable television company, starting with home installations and later 6 advancing to “putting up the telephone poles after the hurricanes came through” all over the 7 country. Id. at 69–70. He stopped working around 2014 due in part to an injury on the job and 8 difficulty finding other jobs, and he pursued inventions, including “a pen that scratches off lottery 9 tickets.” Id. at 71. At times, he worked as a caregiver for his mother and for a cousin. Id. at 72– 10 73. 11 R.M. suffers from diabetes, issues with his knees and back (caused in part by a gunshot 12 wound), and peripheral neuropathy, among other limitations. Because this Order turns on what 13 appears to have been a misunderstanding at the administrative hearing, the Court need not address 14 R.M.’s medical history in detail. 15 R.M. applied for Supplemental Security Income benefits in 2020, when he was fifty-one 16 years old. See id. at 57. After R.M.’s application was denied, he sought review by an 17 administrative law judge (the ALJ). 18 B. Administrative Hearing 19 The ALJ began the administrative hearing by questioning R.M. about his vocational and 20 medical history, as well as his symptoms and limitations. AR at 68–83. R.M.’s attorney also 21 questioned him about those topics. Id. at 83–92. In response to questions from his attorney, R.M. 22 described difficulty gripping and holding onto objects due to a stinging pins-and-needles feeling in 23 his hands, which has not improved with medication. Id. at 88–90. 24 The ALJ questioned a vocational expert (the VE) about R.M.’s past work. AR at 94–95. 25 The VE testified that R.M. performed highly skilled work as a cable television installer and cable 26

27 4 This Order cites page numbers of the Administrative Record as labeled by the Commissioner, 1 repairer, but that his skills from that work would not transfer to any sedentary jobs and would 2 transfer to only a limited number of light work jobs, with only 3,500 positions nationwide. Id. 3 The ALJ asked the VE if jobs would be available for someone of R.M.’s age, education, 4 and work history who was restricted to light work with additional limitations that included (among 5 other restrictions) lifting no more than twenty pounds occasionally and ten pounds frequently, and 6 sitting, standing, and walking for six hours. AR at 94–95. The VE testified that such a person 7 could not perform R.M.’s past work but identified three suitable job categories with a total of 8 97,000 jobs in the national economy. Id. at 96. 9 For a second hypothetical, the ALJ set limitations of lifting fifteen pounds occasionally 10 and frequently, and “[s]itting for six hours, standing for two hours, walking for two hours,” among 11 other restrictions. AR at 96–97. The VE focused on the fifteen-pound lifting restriction, which 12 required the VE to deviate from the Dictionary of Occupational Titles (where light work allows 13 for lifting of up to twenty pounds) and instead rely on her own education and professional 14 experience. Id. at 97–98. After stating that “there certainly are jobs at the light range where there 15 would be more walking and less need for the lifting,” the VE identified the following three job 16 categories as suitable: Ticket Taker, with 5,400 positions nationwide; Parking Lot Attendant, with 17 26,000 positions; and Merchandise Marker with a fifty percent reduction, resulting in 70,000 18 positions. Id. at 97. 19 When R.M.’s attorney began to question the VE, the VE realized that she had not 20 accounted for the standing and walking restrictions in the ALJ’s second hypothetical. AR at 98. 21 The VE stated that “there are Merchandise markers that only stand for four -- stand and walk for 22 four hours out of the day,” and that she would reduce the number of jobs to account for that. Id. at 23 99. A confused exchange followed:

24 [VE:] But based on four hours of standing and walking, there are light jobs that would – 25 [Attorney:] Two hours. 26 [VE:] Yes. 27 [VE:] Right. 1 ATTY: It’s two hours standing, two hours walking. Is that right? Did 2 I misunderstand the hypothetical, Your Honor?

3 ALJ: No, that’s correct.

4 ATTY: Is it a total of four?

5 ALJ: No.

6 ATTY: Oh, okay. Then I misunderstood. Okay. Very good. 7 Id. (emphasis added). 8 The VE concluded that a sixty percent reduction of merchandise maker jobs was 9 warranted, and the “national number remaining . . . with the four hours of standing and walking is 10 going to be approximately 54,000.” AR at 99–100 (emphasis added). No one commented on the 11 discrepancy between the VE’s continued use of a four-hour restriction after the ALJ clarified that 12 was not what he had intended, and R.M.’s attorney had no further questions for the VE. Id. at 100. 13 The ALJ explained the next steps in the process and ended the hearing. Id. at 101–02. 14 C. Legal Standard for Administrative Proceedings 15 The Social Security Administration uses a five-step process to determine whether 16 claimants are entitled to disability benefits:

17 Step 1. Is the claimant presently working in a substantially gainful activity? If so, then the claimant is “not disabled” within the meaning 18 of the Social Security Act and is not entitled to disability insurance benefits. If the claimant is not working in a substantially gainful 19 activity, then the claimant’s case cannot be resolved at step one and the evaluation proceeds to step two. See 20 C.F.R. § 404.1520(b). 20 Step 2.

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