(SS) De Jong v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedOctober 4, 2024
Docket1:24-cv-00381
StatusUnknown

This text of (SS) De Jong v. Commissioner of Social Security ((SS) De Jong 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) De Jong v. Commissioner of Social Security, (E.D. Cal. 2024).

Opinion

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4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 CHRISTOPHER DE JONG, Case No. 1:24-cv-00381-EPG 13 Plaintiff, FINAL JUDGMENT AND ORDER REGARDING PLAINTIFF’S SOCIAL 14 v. SECURITY COMPLAINT 15 COMMISSIONER OF SOCIAL SECURITY, (ECF Nos. 1, 14).

16 Defendant. 17 18 19 This matter is before the Court on Plaintiff’s complaint for judicial review of an 20 unfavorable decision by the Commissioner of the Social Security Administration regarding his 21 application for disability insurance benefits. The parties have consented to entry of final judgment 22 by the United States Magistrate Judge under the provisions of 28 U.S.C. § 636(c), with any 23 appeal to the Court of Appeals for the Ninth Circuit. (ECF No. 20). 24 Here, the parties agree that the ALJ erred—specifically, at Step Five by concluding that a 25 significant number of jobs existed that Plaintiff is capable of performing. The only dispute in this 26 case is the scope of the remand. Plaintiff argues that, on remand, the ALJ should be limited to 27 addressing the Step 5 error. Defendant argues that this case should be remanded on an open 28 2 Having reviewed the record, administrative transcript, parties’ briefs, and the applicable 3 law, the Court finds as follows. 4 I. ANALYSIS 5 A. Step Five 6 At step five, the ALJ must determine whether there are a significant number of jobs 7 available for the claimant in the national economy considering the claimant’s age, education, 8 work experience, and residual functional capacity. Tackett v. Apfel, 180 F.3d 1094, 1099 (9th Cir. 9 1999); 20 C.F.R. § 404.1560(c). In determining what constitutes a significant number of jobs, the 10 Ninth Circuit has characterized 25,000 national jobs as “a close call” but ultimately sufficient. 11 Gutierrez v. Comm’r of Soc. Sec., 740 F.3d 519, 529 (9th Cir. 2014). An ALJ’s determination as 12 to whether work exists in significant numbers must be supported by “substantial evidence,” which 13 “is more than a mere scintilla but less than a preponderance; it is such relevant evidence as a 14 reasonable mind might accept as adequate to support a conclusion.” Id. at 522 (quotation marks 15 and citation omitted). 16 Here, the ALJ found Plaintiff capable of performing three jobs—table worker, sorter, and 17 dowel inspector—which had a total of 19,900 jobs nationally. (A.R. 31). Plaintiff argues that this 18 number is substantially below the 25,000 number that the Ninth Circuit has labeled a “close call” 19 and that, according to a new policy announced by the Commissioner, there are good reasons to 20 conclude that the sorter position is obsolete.1 (ECF No. 14, p. 7, citing Emergency Message (EM) 21 24027, Social Security Administration, June 22, 2024, available at the following web address: 22 https://secure.ssa.gov/apps10/reference.nsf/links/06212024022159PM). Plaintiff concludes by 23 stating: “Because of the ALJ’s thin margin for finding available jobs at step five, removing one 24 occupation makes the step five denial untenable. Thus, remand is necessary to resolve whether 25

26 1 Plaintiff also briefly asserts “that jobs for the occupations at issue currently do not exist anywhere near the numbers testified to at Plaintiff’s hearing” and “that the conflicts between Plaintiff’s adjudicated 27 RFC and the DOT descriptions for the occupations at issue cannot be explained by a VE’s ‘experience and training.”’ (ECF No. 14, p. 6 n.6). He indicates that he may raise these issues on remand. 28 2 Plaintiff can perform.” (Id.). 3 In response, Defendant takes no issue with any of Plaintiff’s arguments. Rather, “[t]he 4 Commissioner concedes that the ALJ erred at step five of the sequential evaluation process.” 5 (ECF No. 16, p. 1). 6 Upon review of Plaintiff’s argument, and considering that Defendant concedes error, the 7 Court concludes that there is not substantial evidence to support the ALJ’s conclusion at Step 5 8 that a significant number of national jobs exist that Plaintiff can perform. Thus, as explained 9 below, the Court will remand this case for the limited purpose of addressing this issue. 10 B. Scope of Remand 11 While the parties agree that the ALJ erred at Step 5, they disagree as to the scope of 12 remand. Plaintiff argues that the ALJ should not be permitted to reconsider the unchallenged 13 findings and that the Court should simply remand the case to allow the ALJ to “cure[] the step 14 five error identified.” (ECF No. 14, p. 9). Defendant argues that “[t]he Court should remand for 15 additional administrative proceedings on an open record.” (ECF No. 16, p. 4). Upon review, the 16 Court concludes that Plaintiff has the better argument. 17 Courts are empowered to—and often do—limit the scope of remand in social security 18 cases: 19 Where a court finds that the Secretary has committed a legal or factual error in evaluating a particular claim, the district court’s remand order will often include 20 detailed instructions concerning the scope of the remand, the evidence to be adduced, and the legal or factual issues to be addressed. See, e.g., Cooper v. 21 Bowen, 815 F.2d 557, 561 (C.A.9, 1987). Often, complex legal issues are 22 involved, including classification of the claimant’s alleged disability or his or her prior work experience within the Secretary’s guidelines or “grids” used for 23 determining claimant disability. See, e.g., Cole v. Secretary of Health and Human 24 Services, 820 F.2d 768, 772–773 (C.A.6, 1987). Deviation from the court’s remand order in the subsequent administrative proceedings is itself legal error, 25 subject to reversal on further judicial review. 26 Sullivan v. Hudson, 490 U.S. 877, 885–86 (1989). 27 Although Defendant contends that the “ordinary remand rule” is to remand on an open 28 record, the case that Defendant cites to support this proposition, Treichler v. Comm’r of Soc. Sec. 2 circumstances under which a court should remand for further administrative proceedings—the 3 ordinary remand rule—or should instead depart from this rule when rare circumstances are 4 present and remand for an award of benefits. Id. at 1099-1102. Nowhere does Treichler instruct 5 that the Court must ordinarily remand for an open record as opposed to limiting the scope of 6 remand with instructions to the Commissioner on what to address. 7 Next comes the question of whether the Court should limit the scope of remand here to the 8 Step Five issue that Plaintiff raises. On this issue, the Court finds Plaintiff’s citation to Brown v. 9 Kijakazi, 11 F.4th 1008 (9th Cir. 2021) persuasive. (ECF No. 14, p. 9). In Brown, the Ninth 10 Circuit rejected the Commissioner’s argument that the Court should remand for a new decision on 11 an entire social security claim: 12 This proceeding does not arise from a direct appeal from a decision of one or more invalidly appointed officers, see Ryder v. United States, 515 U.S. 177, 188, 115 13 S.Ct. 2031, 132 L.Ed.2d 136 (1995), nor is it a direct petition for review that might similarly have brought the entirety of the administrative decision before us, see 14 Lucia v. SEC, ––– U.S. ––––, 138 S. Ct. 2044, 2055, 201 L.Ed.2d 464 (2018).

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Related

Albemarle Paper Co. v. Moody
422 U.S. 405 (Supreme Court, 1975)
Sullivan v. Hudson
490 U.S. 877 (Supreme Court, 1989)
Ryder v. United States
515 U.S. 177 (Supreme Court, 1995)
Carlos Gutierrez v. Commissioner of Social Securit
740 F.3d 519 (Ninth Circuit, 2014)
Lucia v. SEC
585 U.S. 237 (Supreme Court, 2018)
Tackett v. Apfel
180 F.3d 1094 (Ninth Circuit, 1999)

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Bluebook (online)
(SS) De Jong v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-de-jong-v-commissioner-of-social-security-caed-2024.