(SS) Labuga v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedJuly 11, 2025
Docket1:24-cv-00890
StatusUnknown

This text of (SS) Labuga v. Commissioner of Social Security ((SS) Labuga 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) Labuga v. Commissioner of Social Security, (E.D. Cal. 2025).

Opinion

9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11

12 TIFFANY NOEL LABUGA, Case No. 1:24-cv-00890-SAB

13 Plaintiff, ORDER AFFIRMING DECISION OF THE COMMISSIONER OF SOCIAL SECURITY 14 v. (ECF Nos. 14, 18) 15 COMMISSIONER OF SOCIAL SECURITY, 16 Defendant. 17

18 Plaintiff Tiffany Noel Labuga (“Plaintiff”) seeks judicial review of a final decision of the 19 Commissioner of Social Security (“Commissioner”) denying her application for disability 20 benefits pursuant to the Social Security Act. The matter is currently before the Court on the 21 parties’ briefs, which were submitted without oral argument. 22 Plaintiff requests the decision of Commissioner be vacated and the case be remanded for 23 further proceedings, arguing that the decision below was not supported by substantial evidence. 24 Specifically, Plaintiff argues that the Administrative Law Judge (“ALJ”) failed to develop the 25 record and failed to adequately consider the nature and intensity of Plaintiff’s alleged physical 26 symptoms. 27 For the reasons explained herein, the Court will affirm the decision of the Commissioner. 1 I. 2 BACKGROUND 3 A. Procedural History 4 On November 2, 2021, Plaintiff protectively filed a Title II application for a period of 5 disability and disability insurance benefits, alleging disability beginning May 19, 2021. (ECF No. 6 11, Administrative Record (“AR”), 281.) Plaintiff’s application was initially denied on February 7 9, 2022, and denied upon reconsideration on August 27, 2022. (AR 146.) Plaintiff requested 8 before a hearing before an ALJ. On December 6, 2023, Plaintiff, represented by counsel, 9 appeared for a hearing in front of an ALJ where Plaintiff amended her alleged disability onset 10 date to May 26, 2022. (AR 76-77.) Plaintiff and vocation expert (“VE”) Paul Steve Ramirez 11 testified. (AR 17.) On February 28, 2024, the ALJ issued a decision concluding that Plaintiff was 12 not disabled. (AR 29.) On June 5, 2024, the Appeals Council denied Plaintiff’s request for 13 review. (AR 1-5.) 14 B. The ALJ’s Findings of Fact and Conclusions of Law 15 In the decision, the ALJ found that Plaintiff had met the insured status requirements of the 16 Social Security Act through December 31, 2025, and that Plaintiff had not engaged in substantial 17 gainful activity since May 26, 2022, the alleged onset date. (AR. 20.) The ALJ found that 18 Plaintiff had the following severe impairments: cervicalgia; morbid obesity; attention deficit 19 hyperactivity disorder (“ADHD”); major depressive disorder; and generalized anxiety disorders. 20 (Id.) However, Plaintiff did not have an impairment or combination of impairments that met or 21 medically equaled the severity of one of the listed in impairments in 20 C.F.R. Part 404, Subpart 22 P, Appendix 1. (AR 21.) 23 After considering the entire record, the ALJ found that Plaintiff had the residual functional 24 capacity (“RFC”) to perform medium work as defined in 20 C.F.R. 404.1567(c) except Plaintiff is 25 further limited to frequently climb ramps and stairs; occasionally climb ladders, ropes, and 26 scaffolds; frequently balance, stoop, crouch, kneel, and crawl; Plaintiff is able to understand, 27 remember, and carry out simples instructions; Plaintiff can make simple work related decisions; 1 assembly line work; and Plaintiff can occasionally interact with supervisors, co-workers, and the 2 public. (AR 24.) 3 The ALJ then found that that Plaintiff was unable to perform any past relevant work, she 4 was 40 on the alleged onset date, and he had at least a high school education. (AR 27-28.) The 5 ALJ discussed that transferability of job skills was not material to the determination of disability 6 because using the Medical-Vocational Rules as framework supported a finding that Plaintiff was 7 “not disabled,” whether or not Plaintiff had transferrable job skills. (AR 28.) Considering 8 Plaintiff’s age, education, work experience, and RFC, the ALJ found that there were jobs that 9 existed in significant numbers in the national economy that Plaintiff could perform. (Id.) 10 Accordingly, the ALJ concluded that Plaintiff had not been under disability, as defined by the 11 Social Security Act, from May 26, 2022, through the date of the decision, February 28, 2024. 12 (AR 29.) 13 Plaintiff sought timely review of the Commissioner’s decision in the federal courts. (ECF 14 No. 1.) The parties consented to the jurisdiction of the United States Magistrate Judge. (ECF 15 Nos. 7, 9, 10.) Thereafter, the parties filed their briefs on the matter.1 16 II. 17 LEGAL STANDARD 18 A. The Disability Standard 19 To qualify for disability insurance benefits under the Social Security Act, a claimant must 20 show she is unable “to engage in any substantial gainful activity by reason of any medically 21 determinable physical or mental impairment which can be expected to result in death or which has 22 lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 23 1 On December 1, 2022, the Supplemental Rules for Social Security became effective. Rule 5 states, “[t]he action is 24 presented for decision by the parties’ briefs.” Fed. R. Civ. P. Appx. Rule 5. The 2022 Advisory Committee noted that “Rule 5 states the procedure for presenting for decision on the merits a [42 U.S.C.] § 405(g) review action that 25 is governed by the Supplemental Rules.” Fed. R. Civ. P. Appx. Rule 5 advisory committee note 2022. Like an appeal, “the briefs present the action for decision on the merits. This procedure displaces summary judgment or such devices as a joint statement of facts as the means of review on the administrative record.” Id. The 2022 26 Advisory Committee unambiguously clarified that “Rule 5 also displaces local rules or practices that are inconsistent with the simplified procedure established by these Supplemental Rules for treating the action as one for review on 27 the administrative record.” Id. Here, Plaintiff filed a motion for summary judgment, which the Court will construe as a brief in support of his position on whether the Court should affirm, modify, or reverse the decision of the 1 423(d)(1)(A). The Social Security Regulations set out a five-step sequential evaluation process to 2 be used in determining whether a claimant is disabled. 20 C.F.R. § 404.1520;2 Batson v. 3 Comm’r of Soc. Sec. Admin., 359 F.3d 1190, 1194 (9th Cir. 2004). The five steps in the 4 sequential evaluation in assessing whether the claimant is disabled are: 5 Step one: Is the claimant presently engaged in substantial gainful activity? If so, the claimant is not disabled. If not, proceed to step two. 6 Step two: Is the claimant’s alleged impairment sufficiently severe to limit his or her 7 ability to work? If so, proceed to step three. If not, the claimant is not disabled. 8 Step three: Does the claimant’s impairment, or combination of impairments, meet or equal an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1? If so, the 9 claimant is disabled. If not, proceed to step four. 10 Step four: Does the claimant possess the residual functional capacity (“RFC”) to perform his or her past relevant work? If so, the claimant is not disabled. If not, 11 proceed to step five.

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(SS) Labuga v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-labuga-v-commissioner-of-social-security-caed-2025.