Thayer v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedSeptember 8, 2020
Docket2:20-cv-00291
StatusUnknown

This text of Thayer v. Commissioner of Social Security (Thayer 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
Thayer v. Commissioner of Social Security, (W.D. Wash. 2020).

Opinion

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE

8 CARL T.,

9 Plaintiff, CASE NO. C20-0291-MAT

10 v. ORDER RE: SOCIAL SECURITY 11 ANDREW M. SAUL, DISABILITY APPEAL Commissioner of Social Security, 12 Defendant. 13

14 Plaintiff proceeds through counsel in his appeal of a final decision of the Commissioner of 15 the Social Security Administration (Commissioner). The Commissioner denied Plaintiff’s 16 application for Supplemental Security Income (SSI) after a hearing before an Administrative Law 17 Judge (ALJ). Having considered the ALJ’s decision, the administrative record (AR), and all 18 memoranda of record, this matter is AFFIRMED. 19 FACTS AND PROCEDURAL HISTORY 20 Plaintiff was born on XXXX, 1989.1 He has a high school diploma and no documented 21 history of gainful employment. (AR 31.) 22

23 1 Dates of birth must be redacted to the year. Fed. R. Civ. P. 5.2(a)(2) and LCR 5.2(a)(1).

ORDER RE: SOCIAL SECURITY 1 Plaintiff applied for SSI in February 2016. (AR 236-41.) That application was denied and 2 Plaintiff timely requested a hearing. (AR 125-33, 137-46.) 3 In June and August 2018, ALJ Timothy Mangrum held hearings, taking testimony from

4 Plaintiff and a vocational expert (VE). (AR 42-92.) In January 2019, the ALJ issued a decision 5 finding Plaintiff not disabled. (AR 19-32.) Plaintiff timely appealed. The Appeals Council denied 6 Plaintiff’s request for review in January 2020 (AR 2-8), making the ALJ’s decision the final 7 decision of the Commissioner. Plaintiff appealed this final decision of the Commissioner to this 8 Court. 9 JURISDICTION 10 The Court has jurisdiction to review the ALJ’s decision pursuant to 42 U.S.C. § 405(g). 11 DISCUSSION 12 The Commissioner follows a five-step sequential evaluation process for determining 13 whether a claimant is disabled. See 20 C.F.R. §§ 404.1520, 416.920 (2000). At step one, it must

14 be determined whether the claimant is gainfully employed. The ALJ found Plaintiff had not 15 engaged in substantial gainful activity since the application date. (AR 21.) At step two, it must 16 be determined whether a claimant suffers from a severe impairment. The ALJ found severe 17 Plaintiff’s spinal impairment, attention deficit/hyperactivity disorder, affective disorder(s), anxiety 18 disorder(s), and substance use disorder. (AR 21-22.) Step three asks whether a claimant’s 19 impairments meet or equal a listed impairment. The ALJ found that Plaintiff’s impairments did 20 not meet or equal the criteria of a listed impairment. (AR 22-23.) 21 If a claimant’s impairments do not meet or equal a listing, the Commissioner must assess 22 residual functional capacity (RFC) and determine at step four whether the claimant has 23 demonstrated an inability to perform past relevant work. The ALJ found Plaintiff capable of

ORDER RE: SOCIAL SECURITY 1 performing light work with additional limitations: he can frequently stoop, crouch, and climb 2 ladders. He should avoid concentrated exposure to vibration, unprotected heights, and unprotected 3 machinery. He can perform tasks for jobs requiring a specific vocational preparation level of 2 or

4 less. He can otherwise perform simple instructions with simple, routine decisions and few 5 workplace changes. He cannot have public interaction. He can have incidental contact with co- 6 workers but no tandem tasks. He can tolerate occasional supervisor interaction as needed. (AR 7 24.) 8 Because the ALJ found that Plaintiff had no past relevant work (AR 31), the ALJ moved 9 on to step five, where the burden shifts to the Commissioner to demonstrate that the claimant 10 retains the capacity to make an adjustment to work that exists in significant levels in the national 11 economy. With the assistance of the VE, the ALJ found Plaintiff capable of performing 12 representative occupations such as bench assembler, cannery worker, and warehouse checker. (AR 13 31-32.)

14 This Court’s review of the ALJ’s decision is limited to whether the decision is in 15 accordance with the law and the findings supported by substantial evidence in the record as a 16 whole. See Penny v. Sullivan, 2 F.3d 953, 956 (9th Cir. 1993). Substantial evidence means more 17 than a scintilla, but less than a preponderance; it means such relevant evidence as a reasonable 18 mind might accept as adequate to support a conclusion. Magallanes v. Bowen, 881 F.2d 747, 750 19 (9th Cir. 1989). If there is more than one rational interpretation, one of which supports the ALJ’s 20 decision, the Court must uphold that decision. Thomas v. Barnhart, 278 F.3d 947, 954 (9th Cir. 21 2002). 22 Plaintiff argues the ALJ erred in (1) discounting his subjective symptom testimony, (2) 23 assessing certain medical evidence and opinions, (3) assessing lay statements, (4) crafting the RFC

ORDER RE: SOCIAL SECURITY 1 assessment, and (5) relying on VE testimony at step five. Plaintiff also argues that the 2 Commissioner’s failure to process his application for Disabled Adult Child (DAC) benefits 3 constitutes harmful legal error. The Commissioner argues that the ALJ’s decision is supported by

4 substantial evidence and should be affirmed, and that Plaintiff did not properly apply for DAC 5 benefits.2 6 DAC application 7 In agency paperwork filed along with Plaintiff’s request for reconsideration, Plaintiff 8 requested that the Commissioner construe that paperwork as an application for DAC benefits, 9 contending that some of Plaintiff’s impairments had been present since birth and his parents were 10 both retired. (AR 283.) Plaintiff requested that his DAC application be considered alongside his 11 SSI application. (Id.) Plaintiff contends that his DAC application was never processed and the 12 Commissioner adjudicated only his SSI claim. Dkt. 10 at 1-2. 13 According to the Commissioner, because Plaintiff did not complete a form DAC

14 application consistent with 20 C.F.R. § 404.611, Plaintiff’s informal request for DAC benefits was 15 insufficient. Dkt. 11 at 2 n.1. This regulation requires that benefits applications be completed on 16 an approved form, with an inked or electronic signature. See 20 C.F.R. § 404.611 (citing 20 C.F.R. 17 § 422.505). Plaintiff’s appeals report was written in the third person (presumably by Plaintiff’s 18 attorney) and is not a benefits application form. (AR 277-84.) 19 Plaintiff argues in the reply brief that the Commissioner fails to dispute his assignment of 20

2 In the reply brief, Plaintiff contends that the Commissioner’s response brief fails to comply with 21 the Court’s scheduling order (Dkt. 9) because it is 20 pages in length. Dkt. 12 at 1. Plaintiff fails to appreciate that the formatting of briefs is addressed in Local Civil Rule (W.D. Wash.) 7(e)(6), which 22 provides that a brief’s caption and signature block, inter alia, do not count toward page totals.

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Thayer v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thayer-v-commissioner-of-social-security-wawd-2020.