Riddle v. Commissioner of Social Security

CourtDistrict Court, D. Nevada
DecidedSeptember 23, 2019
Docket2:16-cv-02003
StatusUnknown

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

Bluebook
Riddle v. Commissioner of Social Security, (D. Nev. 2019).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 4 BRADLEY A. RIDDLE, Case No. 2:16-cv-02003-JAD-BNW 5 Plaintiff 6 v. Order Granting Motion 7 NANCY A. BERRYHILL, Acting to Remand, Denying Commissioner of Social Security, Cross-Motion to Affirm, and 8 Remanding Case Defendant 9 [ECFNOS.16,17] 10 11 This is Plaintiff Bradley A. Riddle’s action for judicial review of the Commissioner of 12 Social Security’s denial of his application for supplemental security incomeunder Title XVI of 13 the Social Security Act. Because I find that the ALJ erred in two respects, and those errors were 14 not harmless, I grant plaintiff’s motion for reversal or remand,1 deny theCommissioner’s cross- 15 motion to affirm,2 and remand this case for further proceedings. 16 BACKGROUND 17 On March 12, 2012,plaintiff applied for supplemental security income under TitleXVI of 18 the Act, alleging an onset date of July 2, 2006.3 Plaintiff’s claim was denied initiallyand on 19 reconsideration.4 AnAdministrative Law Judge (ALJ) conducted a hearing onJanuary 14, 2015.5 20 On February 4, 2015, the ALJ issued a decision finding that plaintiff is not disabled.6 The ALJ’s 21 decision became the Commissioner’s final decision when the Appeals Council denied reviewon 22 23 1 ECF No. 16. 24 2 ECF Nos. 17 and 18. 25 3 AR 49–52, 137–145. AR refers to the Administrative Record in this matter. See Notice of Manual Filing,ECF No. 11. 26 4 AR 64–67, 71–74. 27 5 AR 32–48. 1 June 23, 2016.7 A month later, plaintiff commenced this action for judicial review under 42 2 U.S.C. §§ 405(g).8 3 DISCUSSION 4 I. Standards of Review 5 A. The underlying disability-evaluation process 6 Anindividual seeking disability benefits has the initial burden of proving disability.9 To 7 meet this burden, the individual must demonstrate the “inability to engage in any substantial 8 gainful activity by reason of any medically determinable physical or mental impairment which 9 can be expected . . . to last for a continuous period of not less than 12 months”10 byproviding 10 “specific medical evidence” in support of his claim for disability.11 If the individual establishes 11 an inability to perform his prior work, then the burden shifts to the Commissioner to show that the 12 individual can perform other substantial gainful work that exists in the national economy.12 13 The ALJ follows a five-stepsequential evaluation process in determining whether an 14 individual is disabled.13 If at any step the ALJ determines that he can make a finding of disability 15 or nondisability, a determination will be made, and no further evaluation is required.14 Step one 16 requires the ALJ to determine whether the individual is engaged in substantial gainful activity 17 (SGA).15 SGA is defined as work activity that is both substantial and gainful; it involves doing 18 significant physical or mental activities usually for pay or profit.16 If the individual is engaged in 19 20 7 AR 1–6. 21 8 See IFP App.,ECF No. 1. 22 9 Roberts v. Shalala, 66 F.3d 179, 182 (9th Cir. 1995). 23 10 42 U.S.C. § 423(d)(1)(A). 24 11 20 C.F.R. § 404.1514. 12 Reddick v. Chater, 157 F.3d 715, 721(9th Cir. 1998). 25 13 See20 C.F.R. § 404.1520; Bowen v. Yuckert, 482 U.S. 137, 140 (1987). 26 14 See20 C.F.R. § 404.1520(a)(4); Barnhart v. Thomas, 540 U.S. 20, 24 (2003). 27 15 20 C.F.R. § 404.1520(b). 1 SGA, then a finding of not disabled is made. If the individual is not engaged in SGA, then the 2 analysis proceeds to step two. 3 Step two addresses whether the individual has a medically determinable impairment that 4 is severe or a combination of impairments that significantly limits him from performing basic 5 work activities.17 An impairment or combination of impairments is not severe when medical and 6 other evidence establishes only a slight abnormality or a combination of slight abnormalities that 7 would have no more than a minimal effect on the individual’s ability to work.18 If the individual 8 does not have a severe medically determinable impairment or combination of impairments, then a 9 finding of not disabled is made. If the individual has a severe medically determinable impairment 10 or combination of impairments, then the analysis proceeds to step three. 11 Step three requires the ALJ to determine whether the individual’s impairments or 12 combination of impairments meet or medically equal the criteria of an impairment listed in 20 13 C.F.R. Part 404, Subpart P, Appendix 1.19 If the individual’s impairment or combination of 14 impairments meets or equals the criteria of a listing and the duration requirement,20 then a finding 15 of disabled is made.21 If the individual’s impairment or combination of impairments does not 16 meet or equal the criteria of a listing or meet the duration requirement, then the analysis proceeds 17 to step four. 18 Before moving to step four, however, the ALJ must first determine the individual’s 19 residual functional capacity (RFC), which is a function-by-function assessment of the individual’s 20 ability to do physical and mental work-related activities on a sustained basis despite limitations 21 22 17 Id.§ 404.1520(c). 23 18 Id.§ 404.1521; see also Social Security Rulings (SSRs) 85-28, 96-3p, and 96-4p. The SSRs constitute the SSA’s official interpretation of the statute and regulations. See Bray v. Comm’r of 24 Soc. Sec. Admin., 554 F.3d 1219, 1224 (9th Cir. 2009); see also20 C.F.R. § 402.35(b)(1). They 25 are entitled to some deference if they are consistent with the Social Security Act and regulations. Bray, 554 F.3d at 1223 (finding ALJ erred in disregarding SSR 82-41). 26 19 20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526. 27 20 20 C.F.R. § 404.1509 1 from impairments.22 In makingthis finding, the ALJ must consider all the relevant evidence, 2 such as all symptoms and the extent to which the symptoms can reasonably be accepted as 3 consistent with the objective medical evidence and other evidence.23 To the extent that 4 statements about the intensity, persistence, or functionally limiting effects of pain or other 5 symptoms are not substantiated by objective medical evidence, the ALJ must make a finding on 6 the credibility of the individual’s statements based on a consideration of the entire case record. 7 The ALJ must also consider opinion evidence in accordance with the requirements of 20 C.F.R. § 8 404.1527 and SSRs 96-2p, 96-5p, 96-6p, and 06-3p. 9 Step four requires the ALJ to determine whether the individual has the RFC to perform his 10 past relevant work (PRW).24 PRW means work performed either as the individual actually 11 performed it or as it is generally performed in the national economy within the last 15 years or 15 12 years before the date that disability must be established.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Barnhart v. Thomas
540 U.S. 20 (Supreme Court, 2003)

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Riddle v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riddle-v-commissioner-of-social-security-nvd-2019.