Priest v. Kijakazi

CourtDistrict Court, E.D. Washington
DecidedSeptember 12, 2023
Docket2:23-cv-00065
StatusUnknown

This text of Priest v. Kijakazi (Priest v. Kijakazi) 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
Priest v. Kijakazi, (E.D. Wash. 2023).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 SHELLY P., NO. 2:23-CV-0065-TOR 8 Plaintiff, ORDER DENYING PLAINTIFF’S 9 v. MOTION TO REMAND CLAIM

10 KILOLO KIJAKAZI, Acting Commissioner of the Social Security 11 Administration,

12 Defendant. 13 BEFORE THE COURT is Plaintiff’s motion for this Court to remand her 14 claim for benefits under Title XVI of the Social Security Act to the Social Security 15 Administration (ECF No. 7) and Defendant’s motion for this Court to affirm the 16 final order of the Acting Commissioner (ECF No. 11). Plaintiff is represented by 17 Christopher H. Dellert. Defendant is represented by Brian M. Donovan, Erin F. 18 Highland, and Jacob P. Phillips. The matter was submitted for consideration 19 without oral argument. The Court has reviewed the administrative record and the 20 parties’ completed briefing and is fully informed. For the reasons discussed below, 1 the Court DENIES Plaintiff’s motion (ECF No. 7) and GRANTS Defendant’s 2 motion (ECF No. 11).

3 JURISDICTION 4 The Court has jurisdiction under 42 U.S.C. §§ 405(g), 1383(c)(3). 5 STANDARD OF REVIEW

6 A district court’s review of a final decision of the Commissioner of Social 7 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 8 limited: the Commissioner’s decision will be disturbed “only if it is not supported 9 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153,

10 1158-59 (9th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence” means 11 relevant evidence that “a reasonable mind might accept as adequate to support a 12 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently,

13 substantial evidence equates to “more than a mere scintilla[,] but less than a 14 preponderance.” Id. (quotation and citation omitted). In determining whether this 15 standard has been satisfied, a reviewing court must consider the entire record as a 16 whole rather than searching for supporting evidence in isolation. Id.

17 In reviewing a denial of benefits, a district court may not substitute its 18 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 19 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one

20 rational interpretation, [the court] must uphold the ALJ’s findings if they are 1 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 2 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an

3 ALJ’s decision on account of an error that is harmless.” Id. An error is harmless 4 “where it is inconsequential to the [ALJ’s] ultimate nondisability determination.” 5 Id. at 1115 (quotation and citation omitted). The party appealing the ALJ’s

6 decision generally bears the burden of establishing that it was harmed. Shinseki v. 7 Sanders, 556 U.S. 396, 409-10 (2009). 8 FIVE-STEP SEQUENTIAL EVALUATION PROCESS 9 A claimant must satisfy two conditions to be considered “disabled” within

10 the meaning of the Social Security Act. First, the claimant must be unable “to 11 engage in any substantial gainful activity by reason of any medically determinable 12 physical or mental impairment which can be expected to result in death or which

13 has lasted or can be expected to last for a continuous period of not less than 12 14 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). Second, the claimant’s 15 impairment must be “of such severity that he is not only unable to do his previous 16 work[,] but cannot, considering his age, education, and work experience, engage in

17 any other kind of substantial gainful work which exists in the national economy.” 18 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B). 19 Pursuant to its authority under the Social Security Act, the Social

20 Security Administration has established a five-step sequential analysis to determine 1 whether a claimant satisfies the above criteria. See 20 C.F.R. § 416.920(a)(4)(i)- 2 (v). At step one, the Commissioner considers the claimant’s work activity. 20

3 C.F.R. § 416.920(a)(4)(i). If the claimant is engaged in “substantial gainful 4 activity,” the Commissioner must find that the claimant is not disabled. 20 C.F.R. 5 § 416.920(b).

6 If the claimant is not engaged in substantial gainful activity, the analysis 7 proceeds to step two. At this step, the Commissioner considers the severity of the 8 claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from 9 “any impairment or combination of impairments which significantly limits [his or

10 her] physical or mental ability to do basic work activities,” the analysis proceeds to 11 step three. 20 C.F.R. § 416.920(c). If the claimant’s impairment does not satisfy 12 this severity threshold, however, the Commissioner must find that the claimant is

13 not disabled. Id. 14 At step three, the Commissioner compares the claimant’s impairment to 15 several impairments recognized by the Commissioner to be so severe as to 16 preclude a person from engaging in substantial gainful activity. 20 C.F.R. §

17 416.920(a)(4)(iii). If the impairment is as severe or more severe than one of the 18 enumerated impairments, the Commissioner must find the claimant disabled and 19 award benefits. 20 C.F.R. § 416.920(d).

20 If the severity of the claimant’s impairment does meet or exceed the severity 1 of the enumerated impairments, the Commissioner must pause to assess the 2 claimant’s “residual functional capacity.” Residual functional capacity (“RFC”) is

3 generally defined as the claimant’s ability to perform physical and mental work 4 activities on a sustained basis despite his or her limitations (20 C.F.R. § 5 416.945(a)(1)), and is relevant to both the fourth and fifth steps of the analysis.

6 At step four, the Commissioner considers whether, in view of the claimant’s 7 RFC, the claimant is capable of performing work that he or she has performed in 8 the past (“past relevant work”). 20 C.F.R. § 416.920(a)(4)(iv). If the claimant is 9 capable of performing past relevant work, the Commissioner must find that the

10 claimant is not disabled. 20 C.F.R. § 416.920(f).

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