Smith v. Saul

CourtDistrict Court, D. Nevada
DecidedFebruary 3, 2022
Docket3:20-cv-00325
StatusUnknown

This text of Smith v. Saul (Smith v. Saul) 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
Smith v. Saul, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 * * * 4 MICHAEL J. SMITH, Case No. 3:20-cv-00325-CLB 5 Plaintiff, ORDER DENYING MOTION TO REMAND AND GRANTING CROSS- 6 v. MOTION TO AFFIRM

7 KILOLO KIJAKAZI,1 [ECF Nos. 19, 20] Acting Commissioner of Social Security, 8 9 Defendant. 10 This case involves the judicial review of an administrative action by the 11 Commissioner of Social Security (“Commissioner”) denying Michael J. Smith’s (“Smith”) 12 application for disability insurance benefits and supplemental security income pursuant to 13 Titles II and XVI of the Social Security Act. Currently pending before the Court is Smith’s 14 motion for reversal and/or remand, (ECF No. 19), and the Commissioner’s cross-motion 15 to affirm and opposition, (ECF No. 20). Having reviewed the pleadings, transcripts, and 16 the Administrative Record (“AR”), (ECF No. 15), the Court concludes that the 17 Commissioner’s finding that Smith could perform other work that exists in significant 18 numbers in the national economy was supported by substantial evidence. Therefore, the 19 Court denies Smith’s motion for remand, (ECF No. 19), and grants the Commissioner’s 20 cross-motion to affirm, (ECF No. 20). 21 I. STANDARDS OF REVIEW 22 A. Judicial Standard of Review 23 This court’s review of administrative decisions in social security disability benefits 24 cases is governed by 42 U.S.C. § 405(g). See Akopyan v. Barnhart, 296 F.3d 852, 854 25 (9th Cir. 2002). Section 405(g) provides that “[a]ny individual, after any final decision of 26 27 1 Kilolo Kijakazi is now the Acting Commissioner of Social Security and is automatically substituted as a party pursuant to Fed. R. Civ. P. 25(d). 28 1 the Commissioner of Social Security made after a hearing to which he was a party, 2 irrespective of the amount in controversy, may obtain a review of such decision by a civil 3 action . . . brought in the district court of the United States for the judicial district in which 4 the plaintiff resides.” The court may enter, “upon the pleadings and transcript of the record, 5 a judgment affirming, modifying, or reversing the decision of the Commissioner of Social 6 Security, with or without remanding the cause for a rehearing.” Id. 7 The court must affirm an Administrative Law Judge’s (“ALJ”) determination if it is 8 based on proper legal standards and the findings are supported by substantial evidence 9 in the record. Stout v. Comm’r Soc. Sec. Admin., 454 F.3d 1050, 1052 (9th Cir. 2006); see 10 also 42 U.S.C. § 405(g) (“findings of the Commissioner of Social Security as to any fact, 11 if supported by substantial evidence, shall be conclusive”). “Substantial evidence is more 12 than a mere scintilla but less than a preponderance.” Bayliss v. Barnhart, 427 F.3d 1211, 13 1214 n.1 (9th Cir. 2005) (internal quotation marks and citation omitted). “It means such 14 relevant evidence as a reasonable mind might accept as adequate to support a 15 conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (quoting Consolidated 16 Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)); see also Webb v. Barnhart, 433 F.3d 17 683, 686 (9th Cir. 2005). 18 To determine whether substantial evidence exists, the court must look at the 19 administrative record as a whole, weighing both the evidence that supports and 20 undermines the ALJ’s decision. Orteza v. Shalala, 50 F.3d 748, 749 (9th Cir. 1995) 21 (citation omitted). Under the substantial evidence test, a court must uphold the 22 Commissioner’s findings if they are supported by inferences reasonably drawn from the 23 record. Batson v. Comm’r, Soc. Sec. Admin., 359 F.3d 1190, 1193 (9th Cir. 2004). 24 “However, if evidence is susceptible of more than one rational interpretation, the decision 25 of the ALJ must be upheld.” Orteza, 50 F.3d at 749 (citation omitted). The ALJ alone is 26 responsible for determining credibility and for resolving ambiguities. Meanel v. Apfel, 172 27 F.3d 1111, 1113 (9th Cir. 1999). 28 It is incumbent on the ALJ to make specific findings so that the court does not 1 speculate as to the basis of the findings when determining if substantial evidence supports 2 the Commissioner’s decision. The ALJ’s findings should be as comprehensive and 3 analytical as feasible and, where appropriate, should include a statement of subordinate 4 factual foundations on which the ultimate factual conclusions are based, so that a 5 reviewing court may know the basis for the decision. See Gonzalez v. Sullivan, 914 F.2d 6 1197, 1200 (9th Cir. 1990). 7 B. Standards Applicable to Disability Evaluation Process 8 The individual seeking disability benefits bears the initial burden of proving 9 disability. Roberts v. Shalala, 66 F.3d 179, 182 (9th Cir. 1995). To meet this burden, the 10 individual must demonstrate the “inability to engage in any substantial gainful activity by 11 reason of any medically determinable physical or mental impairment which can be 12 expected . . . to last for a continuous period of not less than 12 months.” 42 U.S.C. § 13 423(d)(1)(A). More specifically, the individual must provide “specific medical evidence” in 14 support of their claim for disability. See 20 C.F.R. § 404.1514. If the individual establishes 15 an inability to perform their prior work, then the burden shifts to the Commissioner to show 16 that the individual can perform other substantial gainful work that exists in the national 17 economy. Reddick v. Chater, 157 F.3d 715, 721 (9th Cir. 1998). 18 The first step requires the ALJ to determine whether the individual is currently 19 engaging in substantial gainful activity (“SGA”). 20 C.F.R. §§ 404.1520(b), 416.920(b). 20 SGA is defined as work activity that is both substantial and gainful; it involves doing 21 significant physical or mental activities, usually for pay or profit. 20 C.F.R. §§ 404.1572(a)- 22 (b), 416.972(a)-(b). If the individual is currently engaging in SGA, then a finding of not 23 disabled is made. If the individual is not engaging in SGA, then the analysis proceeds to 24 the second step. 25 The second step addresses whether the individual has a medically determinable 26 impairment that is severe or a combination of impairments that significantly limits the 27 individual from performing basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).

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Smith v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-saul-nvd-2022.