Tusitino v. O'Malley

CourtDistrict Court, D. Nevada
DecidedJuly 22, 2025
Docket2:24-cv-01241
StatusUnknown

This text of Tusitino v. O'Malley (Tusitino v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tusitino v. O'Malley, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Saimalo T., Plaintiff(s), 2:24-cv-01241-MDC 4 vs.

5 Martin O'Malley, Commissioner of Social ORDER REMANDING CASE FOR Security, FURTHER ADMINISTRATIVE 6 PROCEEDINGS Defendant(s). 7

8 Pro se plaintiff Saimalo T. filed a Motion for Remand (“Motion”) regarding the Administrative 9 Law Judge’s (“ALJ”) final decision denying her social security benefits. ECF No. 14. The Court the 10 GRANTS Motion because the ALJ’s opinion is not supported by substantial evidence. The ALJ rejected 11 the expert opinions and instead relied on her own judgment in determining the plaintiff’s residual 12 functional capacity. 13 I. BACKGROUND 14 Plaintiff filed applications for a period of disability and disability insurance benefits on August 15 17, 2021 alleging disability commencing July 27, 2020. AR 274-280. The Commissioner denied the 16 claims by initial determination on March 28, 2022. AR 133-143. Plaintiff requested reconsideration of 17 the initial determination on April 1, 2022. AR 171. The Commissioner denied reconsideration on 18 September 15, 2022. AR 145-156. Plaintiff requested a de novo hearing before an ALJ on October 4, 19 2022. AR 197-215. The ALJ conducted a hearing on May 4, 2023. AR 99-132. The ALJ published an 20 unfavorable decision on July 31, 2023. AR 17-36. Plaintiff requested that the Appeals Council review 21 the ALJ’s decision on August 25, 2023. AR 270-271. The Appeals Council denied the request for review 22 on May 9, 2024. AR 1-6. On that date, the ALJ’s decision became the final decision of the 23 Commissioner. 42 U.S.C. § 405(h). The Court has jurisdiction to review the final decision of the 24 Commissioner for substantial evidence and error of law. 42 U.S.C. §§ 405(g); 1383(c). 25 1 The ALJ calculated that plaintiff met the special earnings requirements for a period of disability 2 and disability insurance benefits through December 31, 2025. AR 20, ¶ 1. The ALJ thereafter used the 3 five-step sequential evaluation process to guide the decision. 20 C.F.R. § 404.1520. At step one, the ALJ 4 agreed that plaintiff did not engage in substantial gainful activity since July 27, 2020. AR 22. At step 5 two, the ALJ found that plaintiff suffered from medically determinable severe impairments consisting of 6 degenerative disc disease of the cervical, lumbar and thoracic spine, knee osteoarthritis and obesity. AR 7 22. At step three, the ALJ decided that the impairments did not meet or equal any “listed” impairment. 8 AR 23 (citing 20 C.F.R., Part 404, Subpart P, Appendix 1). The ALJ assessed plaintiff as retaining the 9 residual functional capacity to perform the demands of work as follows: 10 light work as defined in 20 C.F.R. § 404.1567(b) except the claimant is capable of lifting and carrying twenty pounds occasionally and ten pounds frequently; she is 11 capable of standing for six hours and she is capable of walking for six hours, but can 12 total no more than six hours on her feet in a normal eight-hour workday; she can push and pull as much as she can lift and carry; she is capable of occasional 13 overhead reaching bilaterally, but can perform frequent bilateral reaching in all directions; she can climb ramps and stairs, climb ladders, ropes, or scaffolds, kneel, 14 crouch, and crawl occasionally, but can stoop frequently; she can occasionally work 15 at unprotected heights and around moving machinery and mechanical parts and operate a motor vehicle; she can occasionally work in extreme cold, extreme heat 16 and vibration. 17 AR 24. 18 At step four, the ALJ compared the residual functional capacity assessed to the demands of 19 plaintiff’s past relevant work as gambling cashier DOT # 211.462- 022 and a check cashier DOT # 20 211.462-026 and decided that plaintiff could perform that kind of work. AR 30. The ALJ concluded that 21 plaintiff did not suffer from a disability between July 27, 2020, and the date of the decision. AR 31. 22 Plaintiff brings multiple arguments: (1) there was a change in the law that should be applied to 23 her pending case where the regulation is silent; (2) the ALJ erred in finding that plaintiff could stand and 24 walk for six hours in an eight-hour workday in interpreting the residual functional capacity (RFC); and 25 1 (3) the ALJ failed to provide clear and convincing reasons to reject plaintiff’s testimony. ECF No. 14. 2 The Commissioner argues that (1) the recent regulatory changes provide no basis for disturbing the 3 ALJ’s decision; (2) the ALJ reasonably assessed plaintiff’s RFC based on the record as a whole; and (3) 4 the ALJ reasonably discounted plaintiff’s subjective symptom complaints. ECF No. 19. 5 II. DISCUSSION 6 A. Legal Standard 7 The Fifth Amendment prohibits the government from depriving persons of property without due 8 process of law. U.S. Const. amend. V. Social security plaintiffs have a constitutionally protected 9 property interest in social security benefits. Mathews v. Eldridge, 424 U.S. 319 (1976); Gonzalez v. 10 Sullivan, 914 F.2d 1197, 1203 (9th Cir. 1990). Plaintiff bears the burden of showing any error was 11 prejudicial. Molina v. Astrue, 674 F.3d 1104, 1111 (9th Cir. 2012). The substantial evidence threshold 12 “is not high” and “defers to the presiding ALJ, who has seen the hearing up close.” Biestek v. Berryhill, 13 587 U.S. 97, 103, 108 (2019). 14 “On judicial review, an ALJ’s factual findings [are] ‘conclusive’ if supported by ‘substantial 15 evidence.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019) (quoting 42 U.S.C. § 405(g)). The 16 substantial evidence threshold “is not high” and “defers to the presiding ALJ, who has seen the hearing 17 up close.” Id. at 1154, 1157; Ford v. Saul, 950 F.3d 1141, 1159 (9th Cir. 2020) (quoting Biestek); see 18 also Valentine v. Astrue, 574 F.3d 685, 690 (9th Cir. 2009) (substantial evidence “is a highly deferential 19 standard of review”). The District Court’s review is limited. See Treichler v. Comm'r of SSA, 775 F.3d 20 1090, 1093 (9th Cir. 2014) (“It is usually better to minimize the opportunity for reviewing courts to 21 substitute their discretion for that of the agency.”) The Court examines the Commissioner’s decision to 22 determine whether (1) the Commissioner applied the correct legal standards and (2) the decision is 23 supported by “substantial evidence.” Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190, 1193 (9th 24 Cir. 2004). Substantial evidence is defined as “more than a mere scintilla” of evidence. Richardson v. 25 1 Perales, 402 U.S. 389, 401 (1971).

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Tusitino v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tusitino-v-omalley-nvd-2025.