Sanders v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedDecember 18, 2024
Docket2:24-cv-00787
StatusUnknown

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

Bluebook
Sanders v. Commissioner of Social Security Administration, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Kevin L Sanders, No. CV-24-00787-PHX-JAT

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court is Plaintiff Kevin L. Sanders’s appeal from the 16 Commissioner of the Social Security Administration’s (“SSA,” “Commissioner,” or 17 “Defendant”) denial of Social Security benefits. (Doc. 13-3). The appeal is fully briefed 18 (Doc. 17; Doc. 18; Doc. 19), and the Court now rules. 19 I. BACKGROUN\D 20 A. Factual Overview 21 Plaintiff was 36 years old on his alleged disability onset date, and he has a high 22 school education. (Doc. 13-3 at 31). His past relevant work includes cook, painter, 23 warehouse worker, and driver. (Id. at 30). Plaintiff filed his Social Security Disability 24 Insurance (SSDI) benefits application on April 23, 2021, alleging disabilities beginning on 25 February 1, 2021. (Doc. 17 at 1). An ALJ denied Plaintiff’s claim on April 6, 2023, after 26 an administrative hearing. (Doc. 13-3 at 32, 87). The SSA Appeals Council denied a 27 request for review of that decision and adopted the ALJ’s decision as the agency’s final 28 decision on February 16, 2024. (Doc. 17 at 2). 1 A. The SSA’s Five-Step Evaluation Process 2 To qualify for Social Security Disability Insurance benefits, a claimant must show 3 that he “is under a disability.” 42 U.S.C. § 423(a)(1)(E). To be “under a disability,” the 4 claimant must be unable to engage in “substantial gainful activity” due to any medically 5 determinable physical or mental impairment. Id. § 423(d)(1). The impairment must be of 6 such severity that the claimant cannot do his previous work or any other substantial gainful 7 work within the national economy. Id. § 423(d)(2). The SSA has created a five-step 8 sequential evaluation process for determining whether an individual is disabled. See 20 9 C.F.R. § 404.1520(a)(1). The steps are followed in order, and each step is potentially 10 dispositive. See id. § 404.1520(a)(4). 11 At Step One, the ALJ determines whether the claimant is engaging in “substantial 12 gainful activity.” Id. § 404.1520(a)(4)(i). “Substantial gainful activity” is work activity that 13 is (1) “substantial,” i.e., doing “significant physical or mental activities;” and (2) “gainful,” 14 i.e., usually done “for pay or profit.” 20 C.F.R. § 416.972(a)–(b). If the claimant is engaging 15 in substantial gainful work activity, the ALJ will find the claimant is not disabled. Id. § 16 404.1520(a)(4)(i). 17 At Step Two, the ALJ determines whether the claimant has “a severe medically 18 determinable physical or mental impairment” or severe “combination of impairments.” Id. 19 § 404.1520(a)(4)(ii). To be “severe,” the claimant’s impairment must “significantly limit” 20 the claimant’s “physical or mental ability to do basic work activities.” Id. § 404.1520(c). 21 If the claimant does not have a severe impairment or combination of impairments, the ALJ 22 will find the claimant is not disabled. Id. § 404.1520(a)(4)(ii). 23 At Step Three, the ALJ determines whether the claimant’s impairment(s) “meets or 24 equals” an impairment listed in Appendix 1 to Subpart P of 20 C.F.R. Part 404. Id. § 25 404.1520(a)(4)(iii). If so, the ALJ will find the claimant is disabled, but if not, the ALJ 26 must assess the claimant’s “residual functional capacity” (“RFC”) before proceeding to 27 Step Four. Id. §§ 404.1520(a)(4)(iii), 404.1520(e). The claimant’s RFC is his ability 28 perform physical and mental work activities “despite his limitations,” based on all relevant 1 evidence in the case record. Id. § 404.1545(a)(1). To determine RFC, the ALJ must 2 consider all the claimant’s impairments, including those that are not “severe,” and any 3 related symptoms that “affect what [the claimant] can do in a work setting.” Id. §§ 4 404.1545(a)(1)–(2). 5 At Step Four, the ALJ determines whether the claimant has the RFC to perform the 6 physical and mental demands of “his past relevant work.” Id. §§ 404.1520(a)(4)(iv), 7 404.1520(e). “Past relevant work” is work the claimant has “done within the past 15 years, 8 that was substantial gainful activity.” Id. § 404.1560(b)(1). If the claimant has the RFC to 9 perform his past relevant work, the ALJ will find the claimant is not disabled. Id. § 10 404.1520(a)(4)(iv). If the claimant cannot perform his past relevant work, the ALJ will 11 proceed to Step Five in the sequential evaluation process. 12 At Step Five, the final step, the ALJ considers whether the claimant “can make an 13 adjustment to other work,” considering his RFC, age, education, and work experience. Id. 14 § 404.1520(a)(v). If so, the ALJ will find the claimant not disabled. Id. If the claimant 15 cannot make this adjustment, the ALJ will find the opposite. Id. 16 B. The ALJ’s Application of the Factors 17 Here, at Step One, the ALJ concluded that the record established that Plaintiff had 18 not engaged in substantial gainful activity since February 1, 2021, the alleged onset date. 19 (Doc. 13-3 at 23). 20 At Step Two, the ALJ determined that Plaintiff had the following severe 21 impairments: “right shoulder avascular necrosis and right hip arthroplasty for avascular 22 necrosis.” (Id. at 24). 23 At Step Three, the ALJ found that Plaintiff did not have any impairment or 24 combination of impairments that met or medically equaled a listed impairment in Appendix 25 1 to Subpart P of 20 C.F.F. Part 404. (Id. at 26). Subsequently, the ALJ determined that 26 Plaintiff had the RFC to perform light work as defined in 20 C.F.R. § 404.1567(a) and 27 416.967(a), except with the following restrictions: 28 1 He can frequently balance and stoop and can occasionally kneel, crouch, and climb ramps and stairs, but can never crawl 2 or climb ladders, ropes, and scaffolds. He can occasionally 3 reach overhead to the right, reach right to the front, and reach right laterally. The claimant can have occasional exposure to 4 hazards such as moving machinery and unprotected heights. 5 [He can alternate] between sitting and standing for a few minutes as frequently as every half hour without loss of 6 productivity. The claimant requires a handheld assistive device 7 when ambulating.

8 (Id. at 26). 9 At Step Four, the ALJ concluded that Plaintiff was unable to perform any past 10 relevant work. (Id. at 30). At Step Five, the ALJ found that Plaintiff could make sufficient 11 adjustments to perform a significant number of jobs in the national economy given his age, 12 education, work experience, and RFC. (Id. at 31). Examples of such jobs included small 13 products assembler, housekeeping cleaner, and rental clerk. (Id. at 31–32). Accordingly, 14 the ALJ concluded that Plaintiff was not disabled as defined in the Social Security Act 15 from the alleged onset date through September 26, 2023. (Id. at 32). 16 II. LEGAL STANDARD 17 This Court may not set aside a final denial of disability benefits unless the ALJ 18 decision is “based on legal error or not supported by substantial evidence in the record.” 19 Revels v. Berryhill, 874 F.3d 648, 654 (9th Cir. 2017) (quoting Benton ex rel. Benton v. 20 Barnhart, 331 F.3d 1030, 1035 (9th Cir. 2003)). “Substantial” evidence involves “more 21 than a mere scintilla but less than a preponderance.” Thomas v.

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Bluebook (online)
Sanders v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanders-v-commissioner-of-social-security-administration-azd-2024.