Osborne v. O'Malley

CourtDistrict Court, D. Idaho
DecidedMarch 30, 2025
Docket1:24-cv-00175
StatusUnknown

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

Bluebook
Osborne v. O'Malley, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

KELLY LEE O., Case No.: 1:24-cv-00175-REP

Plaintiff, MEMORANDUM DECISION AND ORDER vs.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

Pending is Plaintiff Kelly Lee O.’s “Complaint for Review of Social Security” (Dkt. 1), appealing the Social Security Administration’s denial of her disability claim. This action is brought pursuant to 42 U.S.C. § 405(g). Having carefully considered the record and otherwise being fully advised, the Court enters the following Memorandum Decision and Order. I. ADMINISTRATIVE PROCEEDINGS On December 2, 2020, Plaintiff protectively filed a Title II application for a period of disability and disability insurance benefits, alleging disability beginning July 31, 2019. The claim was originally denied on August 26, 2021, and again on reconsideration on January 7, 2022. On or around February 10, 2022, Plaintiff filed a Request for Hearing before an Administrative Law Judge (“ALJ”). On April 4, 2023, ALJ Christel Ambuehl held an online video hearing (due to the COVID-19 pandemic), at which time Plaintiff, appearing with her attorney Britney Ocampo, testified. Mark J. Schwager, an impartial vocational expert, also appeared and testified at the same hearing. On May 3, 2023, the ALJ issued a decision denying Plaintiff’s claim, finding that Plaintiff was not disabled within the meaning of the Social Security Act. Plaintiff timely requested review from the Appeals Council. On February 7, 2024, the Appeals Council denied Plaintiff’s Request for Review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Plaintiff, having exhausted her administrative remedies, brings this case. She contends the ALJ erred in three respects: (i) the ALJ failed to properly evaluate the medical opinions; (ii) the ALJ failed to provide clear and convincing reasons to disregard Plaintiff’s subjective

symptom allegations; and (iii) the ALJ failed to provide germane reasons to disregard lay witness statements. Pl.’s Brief at 5-20 (Dkt. 14). Plaintiff requests that the Court either reverse the ALJ’s decision and find that she is entitled to benefits, or remand the case for further proceedings. Id. at 20; see also Compl. at 2 (Dkt. 1). II. STANDARD OF REVIEW To be upheld, the Commissioner’s decision must be supported by substantial evidence and based on proper legal standards. 42 U.S.C. § 405(g); Trevizo v. Berryhill, 871 F.3d 664 (9th Cir. 2017). Findings as to any question of fact, if supported by substantial evidence, are conclusive. See 42 U.S.C. § 405(g). If there is substantial evidence to support the ALJ’s factual

decisions, they must be upheld, even when there is conflicting evidence. See Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090, 1098 (9th Cir. 2014). “Substantial evidence” is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971); Ludwig v. Astrue, 681 F.3d 1047, 1051 (9th Cir. 2012). The standard requires more than a scintilla but less than a preponderance. Trevizo, 871 F.3d at 674. It “does not mean a large or considerable amount of evidence.” Pierce v. Underwood, 487 U.S. 552, 565 (1988). With respect to questions of fact, the Court is to review the record as a whole to decide whether it contains evidence that would allow a reasonable mind to accept the conclusions of the ALJ. Richardson, 402 U.S. at 401; see also Ludwig, 681 F.3d at 1051. The ALJ is responsible for determining credibility, resolving conflicts in medical testimony, and resolving ambiguities. Treichler, 775 F.3d at 1098. Where the evidence is susceptible to more than one rational interpretation, the reviewing court must uphold the ALJ’s findings if they are supported by inferences reasonably drawn from the record. Ludwig, 681 F.3d at 1051. In such cases, the reviewing court may not substitute its judgment or interpretation of the record for that of the

ALJ. Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190, 1196 (9th Cir. 2004). The decision must be based on proper legal standards and will be reversed for legal error. Zavalin v. Colvin, 778 F.3d 842, 845 (9th Cir. 2015). Considerable weight is given to the ALJ’s construction of the Social Security Act. See Vernoff v. Astrue, 568 F.3d 1102, 1105 (9th Cir. 2009). However, this Court “will not rubber-stamp an administrative decision that is inconsistent with the statutory mandate or that frustrates the congressional purpose underlying the statute.” Smith v. Heckler, 820 F.2d 1093, 1094 (9th Cir. 1987). III. DISCUSSION A. Sequential Process

In evaluating the evidence presented at an administrative hearing, the ALJ must follow a sequential process in determining whether a person is disabled in general (20 C.F.R. §§ 404.1520, 416.920) – or continues to be disabled (20 C.F.R. §§ 404.1594, 416.994) – within the meaning of the Social Security Act. The first step requires the ALJ to determine whether the claimant is engaged in substantial gainful activity (“SGA”). 20 C.F.R. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). SGA is work activity that is both substantial and gainful. 20 C.F.R. §§ 404.1572, 416.972. “Substantial work activity” is work activity that involves doing significant physical or mental activities. 20 C.F.R. §§ 404.1572(a), 416.972(a). “Gainful work activity” is work that is usually done for pay or profit, whether or not a profit is realized. 20 C.F.R. §§ 404.1572(b), 416.972(b). If the claimant has engaged in SGA, disability benefits are denied regardless of her medical condition, age, education, and work experience. 20 C.F.R. §§ 404.1520(b), 416.920(b). If the claimant has not engaged in SGA, the analysis proceeds to the second step. Here, the ALJ found that Plaintiff has not engaged in SGA since July 31, 2019, the alleged onset date. AR 28. The second step requires the ALJ to determine whether the claimant has a medically

determinable impairment, or combination of impairments, that is severe and meets the duration requirement. 20 C.F.R. §§ 404

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
William Ludwig v. Michael Astrue
681 F.3d 1047 (Ninth Circuit, 2012)
Tommasetti v. Astrue
533 F.3d 1035 (Ninth Circuit, 2008)
Lingenfelter v. Astrue
504 F.3d 1028 (Ninth Circuit, 2007)
Vernoff Ex Rel. Vernoff v. Astrue
568 F.3d 1102 (Ninth Circuit, 2009)
Karen Garrison v. Carolyn W. Colvin
759 F.3d 995 (Ninth Circuit, 2014)
Igor Zavalin v. Carolyn W. Colvin
778 F.3d 842 (Ninth Circuit, 2015)

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Osborne v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/osborne-v-omalley-idd-2025.