Rivera v. Kijakazi

CourtDistrict Court, S.D. California
DecidedFebruary 1, 2024
Docket3:23-cv-00501
StatusUnknown

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

Bluebook
Rivera v. Kijakazi, (S.D. Cal. 2024).

Opinion

2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 VICTOR R., Case No.: 3:23-cv-00501-GPC-BGS

12 Plaintiff, ORDER ON JOINT MOTION FOR 13 v. JUDICIAL REVIEW

14 MARTIN J. O’MALLEY, Commissioner [ECF 15] of Social Security,1 15 Defendant. 16 17 18 On March 20, 2023, Victor R., Plaintiff, filed a Complaint seeking judicial review 19 under 42 U.S.C. § 405(g) of the January 28, 2022, decision of Administrative Law Judge 20 (ALJ) Randolph E. Schum finding that Plaintiff was not disabled under the Social 21 Security Act (AR 1-5). (ECF 1.) The decision became final on January 23, 2023, when 22 the Appeals Council denied review of the ALJ’s decision. 23 This Report and Recommendation is submitted to United States District Judge 24 Gonzalo P. Curiel under 28 U.S.C. § 636(b)(1) and Local Civil Rule 72.1(c). For the 25 following reasons, it is recommended that the final decision of the Commissioner be 26

27 28 1 Martin J. O’Malley, Commissioner of Social Security, is substituted for his predecessor, Kilolo Kijakazi, Acting Commissioner of Social Security, under Fed. R. Civ. P. 25(d). 2 I. Background 3 Plaintiff filed an application for a period of disability and disability insurance 4 benefits on November 2, 2020. (AR 15.2) He alleged disability beginning January 1, 5 2018. (Id.) The claims were denied on April 16, 2021, and on reconsideration, on July 6 30, 2021. (Id.) A telephone hearing was held before ALJ Schum on January 10, 2022. 7 (Id.) 8 After its hearing, the ALJ made the following findings and conclusions under the 9 five-step sequential process. See 20 C.F.R. § 404.1520(a)(4). At step one, the ALJ 10 concluded that “[t]he claimant meets the insured status requirements of the Social 11 Security Act through December 31, 2021” and “has not engaged in substantial gainful 12 activity since January 1, 2018, the alleged onset date (20 CFR 404.1571 et seq., and 13 416.971 et seq.).” (AR 17.) 14 At step two, the ALJ concluded that “[t]he claimant had the following severe 15 impairments: history of coronary artery disease/ischemic heart disease (20 CFR 16 404.1520(c) and 416.920(c)).” (AR 18.) At step two, the ALJ also evaluated the severity 17 of Plaintiff’s medically determinable mental impairments of depression and post- 18 traumatic stress disorder (PTSD) by following the special psychiatric review technique 19 (PRT) using the “paragraph B” criteria described in 20 C.F.R. § 404.1520a. (See AR 19- 20 20.) Using that technique, the ALJ rated the degree of functional limitation Plaintiff had 21 in four areas due to the depression and PTSD: his ability to understand, remember, or 22 apply information; interact with others; concentrate, persist, or maintain pace; and adapt 23 or manage himself. See 20 C.F.R. § 404.1520a(c)(3). Using the PRT, the ALJ rated 24 Plaintiff’s degree of limitation in the four areas by using the five-point scale of “[n]one, 25 mild, moderate, marked, and extreme.” See 20 C.F.R. § 404.1520a(c)(4). The ALJ 26

27 28 2 Unless otherwise indicated, the Court cites to the Administrative Record (AR) in this case (see ECF 8). Citations to the AR are to the page numbers on the original document. 2 functional areas.” (AR 20.) The ALJ then concluded that “the evidence did not 3 otherwise indicate that there was more than a minimal limitation in [Plaintiff’s] ability to 4 do basic work activities,” and that the mental impairments were, therefore, non-severe.3 5 (Id.) 6 At step three, the ALJ concluded that Plaintiff “did not have an impairment or 7 combination of impairments that met or medically equaled the severity of one of the 8 listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 9 404.1525, 404.1526, 416.920(d), 416.925 and 416.926).” (AR 20.) 10 As to Plaintiff’s residual functional capacity (RFC), the ALJ concluded that 11 the claimant had the residual functional capacity to perform light wok as defined in 20 CFR 404.1567(b) and 416.967(b) except 12 the claimant could lift and/or carry 20 pounds occasionally and 13 ten pounds frequently; stand and/or walk six hours in an eight- hour day; sit for six hours in an eight-hour day; never climb 14 ropes, ladders or scaffolds; frequently balance; occasionally 15 climb ramps and stairs, stoop, kneel, crouch, and crawl; and should avoid concentrated exposure to temperature extremes, 16 fumes, odors, dust, and gases, and unprotected heights. 17 (AR 20.) 18 At step four, the ALJ concluded that Plaintiff “was capable of performing past 19 relevant work as a sales representative, data processing services and sales manager. This 20 work did not require the performance of work-related activities precluded by the 21 claimant’s residual functional capacity (20 CFR 404.1565 and 416.965).” (AR 24.) As a 22 result, after its step four conclusion, the ALJ concluded that “[t]he claimant has not been 23 under a disability, as defined in the Social Security Act, from January 1, 2018, through 24 the date of this decision (20 CFR 404.1520(f) and 416.920(f)).” (Id.) 25 II. Issues 26

27 28 3 A rating of the degree of limitation as “none” or “mild” generally results in a conclusion that an impairment is not severe. 20 C.F.R. § 1520a(d). 2 because the ALJ failed to either include the mental limitations he found credible in the 3 dispositive hypothetical question to the VE at step five or in assessing his residual 4 functional capacity or to explain why he was omitting these credible limitations”; and (2) 5 “whether remand is required because the ALJ violated the de minimis standard in finding 6 that Plaintiff’s well-documented mental impairments were not severe.” (ECF 15 at 3.) 7 III. Standard of Review 8 The ALJ’s decision may be reversed only if it is not supported by substantial 9 evidence in the record or if it is based on legal error. Revels v. Berryhill, 874 F.3d 648, 10 654 (9th Cir. 2017). “The ALJ’s determinations of law are reviewed de novo, although 11 deference is owed to a reasonable construction of the applicable statutes.” Edlund v. 12 Massanari, 253 F.3d 1152, 1160 (9th Cir. 2001). “Substantial evidence means more than 13 a mere scintilla, but less than a preponderance. It means such relevant evidence as a 14 reasonable mind might accept as adequate to support a conclusion.” Revels, 874 F.3d at 15 654 (internal quotation marks omitted).

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Bluebook (online)
Rivera v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-kijakazi-casd-2024.