(SS) Gibbs v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedMarch 21, 2024
Docket1:21-cv-00503
StatusUnknown

This text of (SS) Gibbs v. Commissioner of Social Security ((SS) Gibbs 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) Gibbs 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 SERENA ELIZABETH GIBBS, Case No. 1:21-cv-00503-KES-HBK 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO DENY PLAINTIFF’S MOTION FOR 13 v. SUMMARY JUDGMENT, GRANT DEFENDANT’S CROSS-MOTION FOR 14 MARTIN O’MALLEY, SUMMARY JUDGMENT, AND AFFIRM COMMISSIONER OF SOCIAL THE DECISION OF THE COMMISSIONER 15 SECURITY,1 OF SOCIAL SECURITY 2 16 Defendant. (Doc. Nos. 24, 29) 17 FOURTEEN-DAY OBJECTION PERIOD 18 19 Serena Elizabeth Gibbs (“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 Court on the parties’ briefs, which were submitted without oral argument. 23 (Doc. Nos. 24, 29). For the reasons stated, the undersigned RECOMMENDS denying Plaintiff’s 24 motion for summary judgment, granting the Commissioner’s cross-motion for summary 25

26 1 The Court has substituted Martin O’Malley, who has since been appointed the Acting Commissioner of Social Security, as the defendant in this suit. See Fed. R. Civ. P. 25(d). 27 2 This matter was referred to the undersigned pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302 (E.D. Cal. 2022). 28 1 judgment, and affirming the Commissioner’s decision. 2 I. JURISDICTION 3 Plaintiff filed for supplemental security income on January 10, 2018, alleging a disability 4 onset date of March 8, 2017. (AR 320-25). At the hearing, she amended the alleged onset date to 5 January 10, 2018. (AR 44-45). Benefits were denied initially (AR 176-192, 214-19), and upon 6 reconsideration (AR 193-209, 223-28). A hearing was conducted before an Administrative Law 7 Judge (“ALJ”) on October 17, 2019. (AR 40-61). Plaintiff was represented by counsel and 8 testified at the hearing. (Id.). On November 8, 2019, the ALJ issued an unfavorable decision 9 (AR 19-39) and on July 2, 2020, the Appeals Council denied review. (AR 6-11). The matter is 10 before the Court under 42 U.S.C. § 1383(c)(3). 11 II. BACKGROUND 12 The facts of the case are set forth in the administrative hearing and transcripts, the ALJ’s 13 decision, and the briefs of Plaintiff and Commissioner. Only the most pertinent facts are 14 summarized here. 15 Plaintiff was 37 years old at the time of the hearing. (AR 47). She completed tenth grade. 16 (AR 45). She lives with her two children, and she is their primary caretaker. (AR 48-49). 17 Plaintiff has no qualifying past relevant work. (AR 33). Plaintiff testified that he cannot work 18 because her back and hands “give out,” she drops things because her hands are weak, and she 19 cannot stand for too long because her legs get numb. (AR 48). She reported she can do a 20 household task for 10-15 minutes before she needs to take a break for an hour and a half, she lays 21 down in her room for half of every day, she can use her hands for 5 minutes before she has to rest 22 them for 1-2 hours, and she can have social interaction for about one hour per day. (AR 50, 52- 23 53, 55). She has headaches four times a week that last from two to four days and she has to stay 24 in bed all day. (AR 53-54). Plaintiff testified that her mental impairments prevent her from 25 working more than her physical impairments. (AR 55). 26 III. STANDARD OF REVIEW 27 A district court’s review of a final decision of the Commissioner of Social Security is 28 governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is limited; the 1 Commissioner’s decision will be disturbed “only if it is not supported by substantial evidence or 2 is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 (9th Cir. 2012). “Substantial 3 evidence” means “relevant evidence that a reasonable mind might accept as adequate to support a 4 conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, substantial evidence 5 equates to “more than a mere scintilla[,] but less than a preponderance.” Id. (quotation and 6 citation omitted). In determining whether the standard has been satisfied, a reviewing court must 7 consider the entire record as a whole rather than searching for supporting evidence in isolation. 8 Id. 9 In reviewing a denial of benefits, a district court may not substitute its judgment for that of 10 the Commissioner. “The court will uphold the ALJ's conclusion when the evidence is susceptible 11 to more than one rational interpretation.” Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 12 2008). Further, a district court will not reverse an ALJ’s decision on account of an error that is 13 harmless. Id. An error is harmless where it is “inconsequential to the [ALJ’s] ultimate 14 nondisability determination.” Id. (quotation and citation omitted). The party appealing the ALJ’s 15 decision generally bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 16 U.S. 396, 409-10 (2009). 17 IV. SEQUENTIAL EVALUATION PROCESS 18 A claimant must satisfy two conditions to be considered “disabled” within the meaning of 19 the Social Security Act. First, the claimant must be “unable to engage in any substantial gainful 20 activity by reason of any medically determinable physical or mental impairment which can be 21 expected to result in death or which has lasted or can be expected to last for a continuous period 22 of not less than twelve months.” 42 U.S.C. § 1382c(a)(3)(A). Second, the claimant’s impairment 23 must be “of such severity that he is not only unable to do his previous work[,] but cannot, 24 considering his age, education, and work experience, engage in any other kind of substantial 25 gainful work which exists in the national economy.” 42 U.S.C. § 1382c(a)(3)(B). 26 The Commissioner has established a five-step sequential analysis to determine whether a 27 claimant satisfies the above criteria. See 20 C.F.R. § 416.920(a)(4)(i)-(v). At step one, the 28 Commissioner considers the claimant’s work activity. 20 C.F.R. § 416.920(a)(4)(i). If the 1 claimant is engaged in “substantial gainful activity,” the Commissioner must find that the 2 claimant is not disabled. 20 C.F.R. § 416.920(b). 3 If the claimant is not engaged in substantial gainful activity, the analysis proceeds to step 4 two. At this step, the Commissioner considers the severity of the claimant’s impairment. 20 5 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of 6 impairments which significantly limits [his or her] physical or mental ability to do basic work 7 activities,” the analysis proceeds to step three. 20 C.F.R. § 416.920(c).

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