Stucki v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedOctober 29, 2024
Docket3:24-cv-05431
StatusUnknown

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

Bluebook
Stucki v. Commissioner of Social Security, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 8 CHRISTOPHER S., 9 Plaintiff, Case No. C24-5431-MLP 10 v. ORDER 11 COMMISSIONER OF SOCIAL SECURITY, 12 Defendant. 13 I. INTRODUCTION 14 Plaintiff seeks review of the denial of his application for Supplemental Security Income 15 and Disability Insurance Benefits. Plaintiff contends the administrative law judge (“ALJ”) 16 misevaluated the medical opinion evidence and his testimony. (Dkt. # 7.) The Commissioner 17 filed a response arguing that the ALJ’s decision is free of legal error, supported by substantial 18 evidence, and should be affirmed (dkt. # 10), and Plaintiff filed a reply. (Dkt. # 13.) Having 19 considered the ALJ’s decision, the administrative record (“AR”), and the parties’ briefs, the 20 Court AFFIRMS the Commissioner’s final decision and DISMISSES the case with prejudice.1 21 22 23

1 The parties consented to proceed before the undersigned Magistrate Judge. (Dkt. # 3.) 1 II. BACKGROUND 2 Plaintiff was born in 1988, has at least a high school education, and previously worked as 3 a sous chef, line cook, and head chef. AR at 30. Plaintiff was last gainfully employed in March 4 2021. Id. at 20.

5 In June 2021, Plaintiff applied for benefits, alleging disability as of March 2021. AR at 6 18. Plaintiff’s applications were denied initially and on reconsideration, and Plaintiff requested a 7 hearing. Id. After the ALJ conducted a hearing in August 2023, the ALJ issued a decision finding 8 Plaintiff not disabled. Id. at 18-32. 9 Using the five-step disability evaluation process,2 the ALJ found, in pertinent part, 10 Plaintiff has the following severe impairments: lumbar degenerative disc disease; right sacroiliac 11 joint arthritis; bilateral hand osteoarthritis; gastroparesis; anxiety, major depressive disorder; 12 post-traumatic stress disorder. AR at 20. Further, Plaintiff has the residual functional capacity 13 (“RFC”) to perform light work except he can occasionally climb ramps or stairs but never 14 ladders, ropes, or scaffolds; can occasionally stoop, kneel, crouch, or crawl; can frequently

15 handle and finger bilaterally; must avoid frequent exposure to vibration; and is limited to 16 detailed, but not complex, instructions with only occasional interaction with the public. Id. at 24. 17 As the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision is the 18 Commissioner’s final decision. AR at 1-7. Plaintiff appealed the final decision of the 19 Commissioner to this Court. (Dkt. # 1.) 20 III. LEGAL STANDARDS 21 Under 42 U.S.C. § 405(g), this Court may overturn the Commissioner’s denial of social 22 security benefits if the ALJ’s decision rests on legal error or is not supported by substantial 23

2 20 C.F.R. §§ 404.1520, 416.920. 1 evidence. Smartt v. Kijakazi, 53 F.4th 489, 494 (9th Cir. 2022). Substantial evidence is defined 2 as “such relevant evidence as a reasonable mind might accept as adequate to support a 3 conclusion.” Biestek v. Berryhill, 587 U.S. 97, 102-03 (2019) (cleaned up). In applying this 4 standard, the Court must consider the record as a whole to determine whether it contains

5 sufficient evidence to support the ALJ’s findings. Id. 6 Although the Court evaluates the record as a whole, it is not permitted to reweigh the 7 evidence or substitute its judgment for that of the ALJ. Ahearn v. Saul, 988 F.3d 1111, 1115 (9th 8 Cir. 2021). The ALJ is tasked with evaluating testimony, resolving conflicts in the medical 9 evidence, and addressing ambiguities in the record. Smartt, 53 F.4th at 494-95. Where the 10 evidence can be interpreted in more than one rational way, the ALJ’s interpretation must be 11 upheld. Id. Even if the ALJ erred, reversal is not warranted unless the error affected the outcome 12 of the disability determination. Ford v. Saul, 950 F.3d 1141, 1154 (9th Cir. 2020). The party 13 challenging the ALJ’s decision bears the burden of demonstrating harmful error. Shinseki v. 14 Sanders, 556 U.S. 396, 409 (2009).

15 IV. DISCUSSION 16 A. The ALJ Did Not Err in Evaluating Severe Impairments at Step Two 17 Plaintiff argues that the ALJ misevaluated his severe impairments at step two of the 18 sequential disability determination. (Dkt. # 7 at 3-6.) At step two, the ALJ must evaluate the 19 combined effect of all impairments on the claimant’s ability to function, regardless of whether 20 each impairment, individually, is severe. Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). 21 An impairment is severe if it significantly limits a claimant’s ability to perform basic work 22 activities for at least twelve months. 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii). Because step 23 1 two serves as a minimal screening device to eliminate baseless claims, the threshold for severity 2 is low. Toledo v. Comm’r of Soc. Sec., 2024 WL 3029251, at *3 (E.D. Cal. June 17, 2024). 3 Plaintiff contends that the ALJ erred by not finding his impairments severe based on his 4 diagnoses, symptom reports, and lack of success with medication. (Dkt. #7 at 4.) Although

5 Plaintiff claims his providers confirmed his diagnoses and provided treatment, these elements 6 alone do not meet the regulatory standard of significant limitations persisting for at least twelve 7 months. See 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii). Additionally, Plaintiff’s complaints “of 8 pain exhibiting tenderness fatigue, weakness, insomnia, and limited range of motion for more 9 than three months” are insufficient to establish significant, lasting limitations. (Dkt. # 7 at 4.) 10 In challenging the ALJ’s step two determination, Plaintiff points to two records that he 11 claims the ALJ misinterpreted. (Dkt. # 7 at 4 (citing AR at 2237, 2251).) The ALJ considered a 12 note from an appointment where Plaintiff presented with “ongoing widespread joint and back 13 pain” but the physician’s notes indicated the clinical findings were “not classically associated 14 with inflammatory joints.” Id. at 21 (citing id. at 2237). The ALJ also reviewed a treatment note

15 reflecting generally normal range of motion and neurological findings and advising sleep and 16 exercise for symptom management. Id. (citing id. at 2251). While these records describe long 17 term symptom management, they neither describe the twelve-month significant limitations 18 required by regulation nor the frequency or intensity of Plaintiff’s symptoms. Given the lack of 19 evidence supporting Plaintiff’s complaints, the ALJ reasonably concluded that Plaintiff’s 20 fibromyalgia, sacroiliac disorder, and ankylosing spondylitis were not severe impairments. See 21 42 U.S.C. § 423(d)(5) (“An individual shall not be considered to be under a disability unless he 22 furnishes such medical and other evidence of the existence thereof as the Commissioner of 23 Social Security may require”).

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Stucki v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stucki-v-commissioner-of-social-security-wawd-2024.