Olson v. O'Malley

CourtDistrict Court, E.D. Washington
DecidedAugust 6, 2024
Docket2:22-cv-00259
StatusUnknown

This text of Olson v. O'Malley (Olson v. O'Malley) 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
Olson v. O'Malley, (E.D. Wash. 2024).

Opinion

1 Aug 06, 2024

2 SEAN F. MCAVOY, CLERK UNITED STATES DISTRICT COURT 3 EASTERN DISTRICT OF WASHINGTON 4

5 SAMANTHA M. O., NO: 2:22-CV-00259-LRS 6 Plaintiff,

7 v. ORDER REMANDING THE COMMISSIONER’S DECISION 8 MARTIN O’MALLEY, COMMISSIONER OF SOCIAL 9 SECURITY,1

10 Defendant.

11 BEFORE THE COURT are the parties’ briefs.2 ECF Nos. 13, 18. This 12 matter was submitted for consideration without oral argument. Plaintiff is 13 represented by attorney Mark Bunch. Defendant is represented by Special Assistant 14

15 1 Martin O’Malley became the Commissioner of Social Security on December 20, 16 2023. Pursuant to Rule 25(d) of the Rules of Civil Procedure, Martin O’Malley is 17 substituted for Kilolo Kijakazi as the Defendant in this suit. 18 2 Plaintiff's opening brief is labeled a Motion for Summary Judgment. ECF No. 13. 19 However, the supplemental rules for Social Security actions under 42 U.S.C. § 20 405(g) went into effect on December 1, 2022; Rule 5 and Rule 6 state the actions 21 are presented as briefs rather than motions. Fed. R. Civ. P. Supp. Soc. Sec. R. 5, 6. 1 United States Attorney David Burdett. The Court, having reviewed the 2 administrative record and the parties’ briefing, is fully informed. For the reasons 3 discussed below, Plaintiff’s brief, ECF No. 13, is granted and Defendant’s brief, 4 ECF No. 18, is denied.

5 JURISDICTION 6 Plaintiff Samantha M. O. (Plaintiff),3 filed for supplemental security income 7 (SSI) on July 31, 2018, and alleged an onset date of January 1, 2014. Tr. 258-63.

8 Benefits were denied initially, Tr. 126-29, and upon reconsideration, Tr. 133-39. 9 Plaintiff appeared at a hearing before an administrative law judge (ALJ) on July 13, 10 2021. Tr. 71-99. On August 4, 2021, the ALJ issued an unfavorable decision, Tr. 11 19-34, and on September 9, 2022, the Appeals Council denied review. Tr. 1-6. The

12 matter is now before this Court pursuant to 42 U.S.C. § 1383(c)(3). 13 BACKGROUND 14 The facts of the case are set forth in the administrative hearing and transcripts,

15 the ALJ’s decision, and the briefs of Plaintiff and the Commissioner, and are 16 therefore only summarized here. 17 Plaintiff was born in 1984 and was 33 years old at the time the application 18 was filed. Tr. 261. She graduated from high school. Tr. 77. She has training in

20 3 The Court identifies a plaintiff in a Social Security case only by the first name and 21 last initial in order to protect privacy. See Local Civil Rule 5.2(c). 1 aesthetics and was a licensed and certified aesthetician. Tr. 77. She has work 2 experience in hospitality and retail. Tr. 81. She testified she cannot work because 3 she is struggling to stabilize her depression and bipolar disorder with medication. 4 Tr. 82. She has mood swings, gets depressed, and sometimes has a hard time getting

5 out of bed. Tr. 85. When her medication is working, she does not have much 6 problem managing her household, running errands, and taking care of her children 7 all day. Tr. 86-87. She experiences periods when her medication is not working,

8 and she is not able to do much. Tr. 88. She cannot run errands and interact with 9 people because she gets moody and frustrated and cries easily. Tr. 90. On bad days, 10 she has a hard time focusing. Tr. 91. She sometimes has good days for a few weeks 11 or a few months before having two weeks or a month of bad days. Tr. 93. Plaintiff

12 testified she has been clean and sober since May 2015. Tr. 78. 13 STANDARD OF REVIEW 14 A district court’s review of a final decision of the Commissioner of Social

15 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 16 limited; the Commissioner’s decision will be disturbed “only if it is not supported by 17 substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 18 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a reasonable

19 mind might accept as adequate to support a conclusion.” Id. at 1159 (quotation and 20 citation omitted). Stated differently, substantial evidence equates to “more than a 21 mere scintilla[,] but less than a preponderance.” Id. (quotation and citation omitted). 1 In determining whether the standard has been satisfied, a reviewing court must 2 consider the entire record as a whole rather than searching for supporting evidence in 3 isolation. Id. 4 In reviewing a denial of benefits, a district court may not substitute its

5 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 1156 6 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 7 rational interpretation, [the court] must uphold the ALJ’s findings if they are

8 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 9 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an ALJ’s 10 decision on account of an error that is harmless.” Id. An error is harmless “where it 11 is inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1115

12 (quotation and citation omitted). The party appealing the ALJ’s decision generally 13 bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 14 396, 409-10 (2009).

15 FIVE-STEP EVALUATION PROCESS 16 A claimant must satisfy two conditions to be considered “disabled” within the 17 meaning of the Social Security Act. First, the claimant must be “unable to engage in 18 any substantial gainful activity by reason of any medically determinable physical or

19 mental impairment which can be expected to result in death or which has lasted or 20 can be expected to last for a continuous period of not less than twelve months.” 42 21 U.S.C. § 1382c(a)(3)(A). Second, the claimant’s impairment must be “of such 1 severity that he is not only unable to do his previous work[,] but cannot, considering 2 his age, education, and work experience, engage in any other kind of substantial 3 gainful work which exists in the national economy.” 42 U.S.C. § 1382c(a)(3)(B). 4 The Commissioner has established a five-step sequential analysis to determine

5 whether a claimant satisfies the above criteria. See 20 C.F.R. § 416.920(a)(4)(i)-(v). 6 At step one, the Commissioner considers the claimant’s work activity. 20 C.F.R. § 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. § 416.920(b). 9 If the claimant is not engaged in substantial gainful activity, the analysis 10 proceeds to step two. At this step, the Commissioner considers the severity of the 11 claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from

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