Twiggs v. Commissioner of Social Security

CourtDistrict Court, D. Idaho
DecidedSeptember 22, 2025
Docket2:24-cv-00323
StatusUnknown

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

Bluebook
Twiggs v. Commissioner of Social Security, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

SONJA RENEE T., Case No.: 2:24-cv-00323-REP

Plaintiff, MEMORANDUM DECISION AND ORDER vs.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

Pending is Plaintiff Sonja Renee T.’s Complaint (Dkt. 1), appealing the Social Security Administration’s denial of her disability claim. This action is brought pursuant to 42 U.S.C. § 1383(c)(3). Having carefully considered the record and otherwise being fully advised, the Court enters the following Memorandum Decision and Order. I. ADMINISTRATIVE PROCEEDINGS On November 6, 2021, Plaintiff protectively filed an application for supplemental security income, alleging disability beginning November 6, 2021. This application was originally denied on April 25, 2022, and again on reconsideration on October 19, 2022. On or around December 5, 2022, Plaintiff filed a Request for Hearing before an Administrative Law Judge (“ALJ”). On November 1, 2023, ALJ Jesse Shumway held a telephonic hearing, at which time Plaintiff, represented by her attorney Timothy Wendell Anderson, appeared and testified. Francene Geers, an impartial vocational expert, also appeared and testified at the same hearing. On December 8, 2023, the ALJ issued a decision denying Plaintiff’s claim. The ALJ found that Plaintiff was not disabled within the meaning of the Social Security Act. Plaintiff timely requested review from the Appeals Council. On March 21, 2024, the

Appeals Council denied Plaintiff’s Request for Review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Having exhausted her administrative remedies, Plaintiff brings this case. She raises two points of error: the ALJ (i) disregarded particular aspects of the state agency psychological consultants’ prior administrative findings (“PAMFs”) without adequate

explanation, and (ii) improperly analyzed the consultants’ PAMFs in any event. Pl.’s Brief at 3-9 (Dkt. 15). Plaintiff in turn requests that the Court reverse the ALJ’s decision and remand for further proceedings. Id. at 9. II. STANDARD OF REVIEW To be upheld, the Commissioner’s decision must be supported by substantial

evidence and based on proper legal standards. 42 U.S.C. §§ 405(g), 1383(c)(3) (applying 42 U.S.C. § 405(g)); Trevizo v. Berryhill, 871 F.3d 664 (9th Cir. 2017). Findings as to any question of fact, if supported by substantial evidence, are conclusive. See 42 U.S.C. § 405(g). If there is substantial evidence to support the ALJ’s factual decisions, they must be upheld, even when there is conflicting evidence. See Treichler v. Comm’r of

Soc. Sec. Admin., 775 F.3d 1090, 1098 (9th Cir. 2014). “Substantial evidence” is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971). The standard requires more than a scintilla but less than a preponderance. Trevizo, 871 F.3d at 674. It “does not mean a large or considerable amount of evidence.” Pierce v. Underwood, 487 U.S. 552, 565 (1988). With respect to questions of fact, the Court is to review the record as a whole to

decide whether it contains evidence that would allow a reasonable mind to accept the conclusions of the ALJ. Richardson, 402 U.S. at 401; see also Ludwig, 681 F.3d at 1051. The ALJ is responsible for determining credibility, resolving conflicts in medical testimony, and resolving ambiguities. Treichler, 775 F.3d at 1098. Where the evidence is susceptible to more than one rational interpretation, the reviewing court must uphold

the ALJ’s findings if they are supported by inferences reasonably drawn from the record. Ludwig, 681 F.3d at 1051. In such cases, the reviewing court may not substitute its judgment or interpretation of the record for that of the ALJ. Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190, 1196 (9th Cir. 2004). The decision will be reversed for legal error. Zavalin v. Colvin, 778 F.3d 842, 845

(9th Cir. 2015). Considerable weight is given to the ALJ’s construction of the Social Security Act. See Vernoff v. Astrue, 568 F.3d 1102, 1105 (9th Cir. 2009). However, this Court “will not rubber-stamp an administrative decision that is inconsistent with the statutory mandate or that frustrates the congressional purpose underlying the statute.” Smith v. Heckler, 820 F.2d 1093, 1094 (9th Cir. 1987).

III. DISCUSSION A. Sequential Process In evaluating the evidence presented at an administrative hearing, the ALJ must follow a sequential process in determining whether a person is disabled in general (20 C.F.R. §§ 404.1520, 416.920) – or continues to be disabled (20 C.F.R. §§ 404.1594, 416.994) – within the meaning of the Social Security Act. The first step requires the ALJ to determine whether the claimant is engaged in

substantial gainful activity (“SGA”). 20 C.F.R. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). SGA is work activity that is both substantial and gainful. 20 C.F.R. §§ 404.1572, 416.972. “Substantial work activity” is work activity that involves doing significant physical or mental activities. 20 C.F.R. §§ 404.1572(a), 416.972(a). “Gainful work activity” is work that is usually done for pay or profit, whether or not a profit is realized.

20 C.F.R. §§ 404.1572(b), 416.972(b). If the claimant has engaged in SGA, disability benefits are denied regardless of her medical condition, age, education, and work experience. 20 C.F.R. §§ 404.1520(b), 416.920(b). If the claimant has not engaged in SGA, the analysis proceeds to the second step. Here, the ALJ found that Plaintiff has not engaged in SGA since November 6, 2021, the application and alleged onset date. AR 22.

The second step requires the ALJ to determine whether the claimant has a medically determinable impairment, or combination of impairments, that is severe and meets the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii).

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Richardson v. Perales
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Pierce v. Underwood
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Karen Garrison v. Carolyn W. Colvin
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Igor Zavalin v. Carolyn W. Colvin
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Trevizo v. Berryhill
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