Rycroft v. Commissioner of Social Security

CourtDistrict Court, D. Nevada
DecidedMarch 17, 2020
Docket2:19-cv-00225
StatusUnknown

This text of Rycroft v. Commissioner of Social Security (Rycroft 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
Rycroft v. Commissioner of Social Security, (D. Nev. 2020).

Opinion

3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 * * * 6 CAROLYN G. RYCROFT, Case No. 2:19-cv-00225-BNW 7 Plaintiff 8 ORDER v. 9 ANDREW SAUL, Acting Commissioner of 10 Social Security,

11 Defendant

12 13 This matter was referred to the undersigned magistrate judge on consent under 28 U.S.C. 14 § 636(c). (ECF No. 25.) The case involves review of an administrative action by the 15 Commissioner of Social Security denying Plaintiff Carolyn G. Rycroft’s application for 16 supplemental security income under Title XVI of the Social Security Act. The court reviewed 17 Plaintiff’s motion for summary judgment (ECF No. 18), filed July 2, 2019, and the 18 Commissioner’s response and cross-motion to affirm (ECF No. 21), filed July 25, 2019. Plaintiff 19 did not file a reply. 20 I. BACKGROUND 21 1. Procedural History 22 On November 18, 2014, Plaintiff applied for supplemental security income under Title 23 XVI of the Act, alleging an onset date of January 25, 2011. AR1 210-218. Plaintiff’s claim was 24 denied initially and on reconsideration. AR 129-132, 139-144. A hearing was held before an 25 Administrative Law Judge (“ALJ”) on July 6, 2017. AR 41-75. On January 12, 2018, the ALJ 26  Andrew Saul has been substituted for his predecessor in office, Nancy A. Berryhill, pursuant to 27 Federal Rule of Civil Procedure 25(d). 1 issued a decision finding that Plaintiff was not disabled. AR 10-28. The ALJ’s decision became 2 the Commissioner’s final decision when the Appeals Council denied review. AR 1-6. Plaintiff, 3 on February 6, 2019, commenced this action for judicial review under 42 U.S.C. § 405(g). (See 4 IFP App. (ECF No. 1).) 5 II. DISCUSSION 6 1. Standard of Review 7 Administrative decisions in social security disability benefits cases are reviewed under 42 8 U.S.C. § 405(g). See Akopyan v. Barnhart, 296 F.3d 852, 854 (9th Cir. 2002). Section 405(g) 9 provides that “[a]ny individual, after any final decision of the Commissioner of Social Security 10 made after a hearing to which [s]he was a party, irrespective of the amount in controversy, may 11 obtain a review of such decision by a civil action . . . brought in the district court of the United 12 States for the judicial district in which the plaintiff resides.” The court may enter “upon the 13 pleadings and transcripts of the record, a judgment affirming, modifying, or reversing the 14 decision of the Commissioner of Social Security, with or without remanding the cause for a 15 rehearing.” Id. 16 The Commissioner’s findings of fact are conclusive if supported by substantial evidence. 17 See 42 U.S.C. § 405(g); Ukolov v. Barnhart, 420 F.3d 1002, 1004 (9th Cir. 2005). However, the 18 Commissioner’s findings may be set aside if they are based on legal error or not supported by 19 substantial evidence. See Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 1052 (9th Cir. 20 2006); Thomas v. Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). The Ninth Circuit defines 21 substantial evidence as “more than a mere scintilla but less than a preponderance; it is such 22 relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” 23 Andrews v. Shalala, 53 F.3d 1035, 1039 (9th Cir. 1995); see also Bayliss v. Barnhart, 427 F.3d 24 1211, 1214 n.1 (9th Cir. 2005). In determining whether the Commissioner’s findings are 25 supported by substantial evidence, the court “must review the administrative record as a whole, 26 weighing both the evidence that supports and the evidence that detracts from the Commissioner’s 27 conclusion.” Reddick v. Chater, 157 F.3d 715, 720 (9th Cir. 1998); see also Smolen v. Chater, 80 1 Under the substantial evidence test, findings must be upheld if supported by inferences 2 reasonably drawn from the record. Batson v. Commissioner of Social Security, 359 F.3d 1190, 3 1193 (9th Cir. 2004). When the evidence will support more than one rational interpretation, the 4 court must defer to the Commissioner’s interpretation. See Burch v. Barnhart, 400 F.3d 676, 679 5 (9th Cir. 2005); Flaten v. Sec’y of Health and Human Serv., 44 F.3d 1453, 1457 (9th Cir. 1995). 6 Consequently, the issue before the court is not whether the Commissioner could reasonably have 7 reached a different conclusion, but whether the final decision is supported by substantial 8 evidence. It is incumbent on the ALJ to make specific findings so that the court does not 9 speculate as to the basis of the findings when determining if the Commissioner’s decision is 10 supported by substantial evidence. Mere cursory findings of fact without explicit statements as to 11 what portions of the evidence were accepted or rejected are not sufficient. Lewin v. Schweiker, 12 654 F.2d 631, 634 (9th Cir. 1981). The ALJ’s findings “should be as comprehensive and 13 analytical as feasible, and where appropriate, should include a statement of subordinate factual 14 foundations on which the ultimate factual conclusions are based.” Id. 15 2. Disability Evaluation Process 16 The individual seeking disability benefits has the initial burden of proving disability. 17 Roberts v. Shalala, 66 F.3d 179, 182 (9th Cir 1995). To meet this burden, the individual must 18 demonstrate the “inability to engage in any substantial gainful activity by reason of any medically 19 determinable physical or mental impairment which can be expected . . . to last for a continuous 20 period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). The individual must also provide 21 “specific medical evidence” in support of her claim for disability. 20 C.F.R. § 404.1514. If the 22 individual establishes an inability to perform her prior work, then the burden shifts to the 23 Commissioner to show that the individual can perform other substantial gainful work that exists 24 in the national economy. Reddick, 157 F.3d at 721. 25 The ALJ follows a five-step sequential evaluation process in determining whether an 26 individual is disabled. See 20 C.F.R. § 404.1520; Bowen v. Yuckert, 482 U.S. 137, 140 (1987).

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