Salazar v. Dudek

CourtDistrict Court, E.D. Washington
DecidedFebruary 18, 2025
Docket1:24-cv-03108
StatusUnknown

This text of Salazar v. Dudek (Salazar v. Dudek) 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
Salazar v. Dudek, (E.D. Wash. 2025).

Opinion

FILED IN THE 4 EASTERU N. S D. I SD TI RS IT CR TI C OT F C WO AU SR HT I NGTON Feb 18, 2025 5 SEAN F. MCAVOY, CLERK 6

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF WASHINGTON 10 JUAN ANTONIO S., 11 No: 1:24-cv-03108-RLP Plaintiff, 12 v. ORDER AFFIRMING THE 13 COMMISSIONER’S DECISION LELAND DUDEK, ACTING 14 COMMISSIONER OF SOCIAL SECURITY,1 15

16 Defendant.

17 18

19 1 On February 18, 2025, Leland Dudek became the Acting Commissioner of 20 Social Security. Pursuant to Rule 25(d) of the Rules of Civil Procedure, Leland 21 Dudek is substituted for Carolyn Colvin as the Defendant in this suit. 1 BEFORE THE COURT is an appeal from an Administrative Law Judge 2 (ALJ) final decision denying disability income benefits under Title II of the Social 3 Security Act. ECF No. 7. The Court considered the matter without oral argument. 4 For the reasons discussed below, the Court concludes the ALJ did not err by failing

5 to apply a disability freeze period to extend Mr. S.’s date last insured. Because Mr. 6 S.’s disability freeze argument is unsuccessful, Mr. S.’s other assignments of error 7 also fail. Therefore, Mr. S.’s brief, ECF No. 7, is denied and the Commissioner’s

8 brief, ECF No. 13, is granted. 9 BACKGROUND 10 The facts of the case are set forth in the administrative hearings and 11 transcripts, the ALJ’s decision, and the briefs of Plaintiff and the Commissioner, and

12 are therefore require only brief summary. 13 In 2012, Mr. S. was sustained a neck injury while working as a manual laborer 14 in a meat warehouse. He had neck surgery in January 2013. Tr. 65, 1826. The

15 surgery resolved some symptoms, but he still claimed to suffer from muscle 16 tightness and pain. Tr. 69. Mr. S. experiences anxiety, depression, and panic attacks, 17 which he testified worsened after his 2013 neck surgery. Tr. 65, 73, 1828. According

18 to Mr. S., anxiety and depression impact his ability to concentrate and communicate. 19 Tr. 74. 20 Mr. S. filed this claim for disability insurance benefits in November 2019, 21 alleging his ability to work is limited by anxiety, depression, and panic attacks, and 1 that his neck injury limits his mobility and ability to focus and perform daily tasks. 2 Tr. 303. 3 ANALYSIS 4 To qualify for disability benefits under Title II of the Social Security Act, a

5 claimant must establish he was disabled prior to the date he was last insured. See 42 6 U.S.C. § 423(c); 20 C.F.R. § 404.1520. Here, the ALJ determined Mr. S. was last 7 insured on December 31, 2017. The ALJ also found that Mr. S. was disabled as of

8 July 2, 2012. However, the ALJ found Mr. S.’s condition had improved and his 9 disability therefore ended on October 1, 2015. Because the ALJ found Mr. S. was no 10 longer disabled as of his last date insured, benefits were denied. 11 Mr. S. argues that the ALJ committed legal error in failing to extend his last

12 date insured. Mr. S. does not dispute that December 31, 2017, is his properly 13 calculated date last insured based on quarters of earned coverage. But Mr. S. argues 14 the ALJ should have applied a disability freeze from July 2, 2012 to October 1,

15 2015. According to Mr. S., the disability freeze would have extended his last date 16 insured by over three years; i.e., into mid-2021. Furthermore, because Mr. S. alleges 17 he again became disabled in 2019, he contends the ALJ committed legal error by

18 failing to assess whether Mr. S. was disabled as of his date last insured. 19 While this Court reviews an ALJ’s factual determinations for substantial 20 evidence, allegations of legal error are reviewed de novo. Mingo v. Heckler, 745 21 F.2d 537, 538 (9th Cir. 1984). 1 Mr. S.’s reference to the concept of a disability freeze comes from the Social 2 Security Administration’s Program Operations Manual System (POMS) which 3 defines a “disability freeze” as a “period of disability during which earnings are 4 eliminated from computation.”2 POMS DI 26001.010. The purpose of the disability

5 freeze is to eliminate years of low earnings due to disability from the computation of 6 benefits and preserve insured status. POMS DI 10105.005A. 7 The federal regulations do not use the term “disability freeze.” Rather, they

8 provide as follows: 9 (a) General. A period of disability is a continuous period of time during which you are disabled. If you become disabled, you may 10 apply to have our records show how long your disability lasts. You may do this even if you do not qualify for disability benefits. If we 11 establish a period of disability for you, the months in that period of time will not be counted in figuring your average 12 earnings. If benefits payable on your earnings record would be

13 2 Agency policy set forth in POMS may be persuasive authority, Warre v. 14 Comm’r of Soc. Sec. Admin., 439 F.3d 1001, 1005 (9th Cir. 2006), but “does not 15 impose judicially enforceable duties on either [the] court or the ALJ.” Carillo- 16 Yeras, 671 F.3d 731, 735 (9th Cir. 2011); see also Lockwood v. Comm’r, 616 F.3d 17 1068, 1073 (9th Cir. 2010) (“POMS does not impose judicially enforceable duties 18 on the SSA”); Durden v. Colvin, 549 Fed. App’x 690, 690-91 (9th Cir. 2013) (“the 19 POMS does not have the force and effect of law and, thus, does not impose 20 judicially enforceable duties on the ALJ”). 21 1 denied or reduced because of a period of disability, the period of disability will not be taken into consideration. 2 (b) Who is entitled. You are entitled to a period of disability if you 3 meet all the following conditions:

4 (1) You have or had a disability as defined in § 404.1505.

5 (2) You are insured for disability, as defined in § 404.130 in the calendar quarter in which you became disabled, 6 or in a later calendar quarter in which you were disabled. 7 (3) You file an application while disabled, or no later 8 than 12 months after the month in which your period of disability ended. If you were unable to apply 9 within the 12-month period after your period of disability ended because of a physical or mental 10 condition as described in § 404.322, you may apply not more than 36 months after the month your 11 disability ended.

12 (4) At least 5 consecutive months go by from the month in which your period of disability begins and before 13 the month in which it would end.

14 20 C.F.R. § 404.320 (emphasis added). 15 As used in the regulations, the phrase “period of disability” is a term of art. 16 “It does not mean simply a period during which a person is disabled and not 17 working.” Sprow v. Bowen, 865 F.2d 207, 208 (9th Cir.1989). Instead, “[t]he 18 person must, in addition, be insured.” Id. The impact of a period of disability on a 19 claimant’s insured status is set by 20 C.F.R. § 404.110(c). 20 It is undisputed that Mr. S. was not disabled at the time of his last date 21 insured 2017; yet he did not apply for Title II benefits until 2019, after the alleged 1 recurrence of his disability. Given this timeline, he receives no benefit from 2 application of a disability freeze.

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