(SS) Anderson v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedJanuary 5, 2024
Docket1:21-cv-00710
StatusUnknown

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

Bluebook
(SS) Anderson v. Commissioner of Social Security, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 LUPE ELIZABETH ANDERSON, Case No. 1:21-cv-00710-JLT-HBK 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO GRANT PLAINTIFF’S MOTION FOR 13 v. SUMMARY JUDGMENT, DENY DEFENDANT’S CROSS-MOTION FOR 14 MARTIN O’MALLEY, SUMMARY JUDGMENT, AND REMAND COMMISSIONER OF SOCIAL CASE TO THE COMMISSIONER OF 15 SECURITY,1 SOCIAL SECURITY2 16 Defendant. (Doc. Nos. 20, 23) 17 FOURTEEN-DAY OBJECTION DEADLINE

18 19 Lupe Elizabeth Anderson (“Plaintiff”), seeks judicial review of a final decision of the 20 Commissioner of Social Security (“Commissioner” or “Defendant”) denying her application for 21 supplemental security income under the Social Security Act. (Doc. No. 1). The matter is 22 currently before the undersigned on the parties’ briefs, which were submitted without oral 23 argument. (Doc. Nos. 20, 23). For the reasons stated, the undersigned RECOMMENDS granting 24 Plaintiff’s motion for summary judgment, denying the Commissioner’s construed cross-motion 25 for summary judgment, and remanding for further administrative proceedings. 26 1 The Court has substituted Martin O’Malley, who has been appointed the Acting Commissioner of Social 27 Security, as the defendant in this suit. See Fed. R. Civ. P. 25(d). 2 This matter was referred to the undersigned pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 28 302(c)(15) (E.D. Cal. 2022). 1 I. JURISDICTION 2 Plaintiff filed for supplemental security income on October 30, 2018, alleging a disability 3 onset date of November 11, 2016. (AR 233-36). At the hearing, she amended the alleged onset 4 date to October 30, 2018. (AR 40). Benefits were denied initially (AR 102-14, 140-45), and 5 upon reconsideration (AR 116-32, 149-54). A telephonic hearing was conducted before an 6 Administrative Law Judge (“ALJ”) on September 14, 2020. (AR 30-62). Plaintiff was 7 represented by counsel and testified at the hearing. (Id.). On October 29, 2020, the ALJ issued 8 an unfavorable decision (AR 13-29) and on March 2, 2021, the Appeals Council denied review. 9 (AR 1-6). The matter is before the Court under 42 U.S.C. § 1383(c)(3). 10 II. BACKGROUND 11 The facts of the case are set forth in the administrative hearing and transcripts, the ALJ’s 12 decision, and the briefs of Plaintiff and Commissioner. Only the most pertinent facts are 13 summarized here. 14 Plaintiff was 49 years old at the time of the hearing. (AR 41). She completed twelfth 15 grade and was in special education classes. (AR 45, 47-48). Plaintiff testified that had been 16 living with her mom, but moved in with her sister a few days before the hearing. (AR 42-43). 17 She has no relevant work history. (AR 58). Plaintiff testified that she was fired from her first 18 “job” because she could not follow instructions. (AR 49). She reported her mental health issues 19 are “the most problematic” of her conditions. (AR 51). She has difficulties with anger problems, 20 needs to have things repeated, needs assistance to fill out paperwork and get to her doctor’s 21 appointments, and requires reminders to take medication. (AR 51-53). Plaintiff testified she has 22 thoughts of self-harm every two to three weeks, but has only made a physical attempt to hurt 23 herself on one occasion. (AR 53-54). She reported difficulty concentrating and pain in her back 24 and knee. (AR 54-55). Plaintiff testified she can stand for about 30 minutes before she has to sit, 25 cannot walk for more than 30 minutes at a time, can sit for 10 to 15 minutes before she has to lay 26 down, and can lift and carry two gallons of milk. (AR 55). 27 III. STANDARD OF REVIEW 28 A district court’s review of a final decision of the Commissioner of Social Security is 1 governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is limited; the 2 Commissioner’s decision will be disturbed “only if it is not supported by substantial evidence or 3 is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 (9th Cir. 2012). “Substantial 4 evidence” means “relevant evidence that a reasonable mind might accept as adequate to support a 5 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, substantial evidence 6 equates to “more than a mere scintilla[,] but less than a preponderance.” Id. (quotation and 7 citation omitted). In determining whether the standard has been satisfied, a reviewing court must 8 consider the entire record as a whole rather than searching for supporting evidence in isolation. 9 Id. 10 In reviewing a denial of benefits, a district court may not substitute its judgment for that of 11 the Commissioner. “The court will uphold the ALJ’s conclusion when the evidence is susceptible 12 to more than one rational interpretation.” Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 13 2008). Further, a district court will not reverse an ALJ’s decision on account of an error that is 14 harmless. Id. An error is harmless where it is “inconsequential to the [ALJ’s] ultimate 15 nondisability determination.” Id. (quotation and citation omitted). The party appealing the ALJ’s 16 decision generally bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 17 U.S. 396, 409-10 (2009). 18 IV. FIVE-STEP SEQUENTIAL EVALUATION PROCESS 19 A claimant must satisfy two conditions to be considered “disabled” within the meaning of 20 the Social Security Act. First, the claimant must be “unable to engage in any substantial gainful 21 activity by reason of any medically determinable physical or mental impairment which can be 22 expected to result in death or which has lasted or can be expected to last for a continuous period 23 of not less than twelve months.” 42 U.S.C. § 1382c(a)(3)(A). Second, the claimant’s impairment 24 must be “of such severity that he is not only unable to do his previous work[,] but cannot, 25 considering his age, education, and work experience, engage in any other kind of substantial 26 gainful work which exists in the national economy.” 42 U.S.C. § 1382c(a)(3)(B). 27 The Commissioner has established a five-step sequential analysis to determine whether a 28 claimant satisfies the above criteria. See 20 C.F.R. § 416.920(a)(4)(i)-(v). At step one, the 1 Commissioner considers the claimant’s work activity. 20 C.F.R. § 416.920(a)(4)(i). If the 2 claimant is engaged in “substantial gainful activity,” the Commissioner must find that the 3 claimant is not disabled. 20 C.F.R. § 416.920(b). 4 If the claimant is not engaged in substantial gainful activity, the analysis proceeds to step 5 two. At this step, the Commissioner considers the severity of the claimant’s impairment. 20 6 C.F.R. § 416.920(a)(4)(ii).

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(SS) Anderson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-anderson-v-commissioner-of-social-security-caed-2024.