Vankeulen v. O'Malley

CourtDistrict Court, E.D. Washington
DecidedSeptember 5, 2024
Docket1:23-cv-03047
StatusUnknown

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

Bluebook
Vankeulen v. O'Malley, (E.D. Wash. 2024).

Opinion

2 FILED IN THE U.S. DISTRICT COURT 3 EASTERN DISTRICT OF WASHINGTON

Sep 05, 2024 4 SEAN F. MCAVOY, CLERK

5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 JAMIE MARIE V., 8 No: 1:23-cv-03047-LRS Plaintiff, 9 v. ORDER REMANDING THE 10 COMMISSIONER’S DECISION MARTIN O’MALLEY, 11 COMMISSIONER OF SOCIAL SECURITY,1 12

13 Defendant.

14 BEFORE THE COURT are the parties’ briefs. ECF Nos. 9, 15. This matter 15 was submitted for consideration without oral argument. Plaintiff is represented by 16 attorney D. James Tree. Defendant is represented by Special Assistant United States 17 Attorney Frederick Fripps. The Court, having reviewed the administrative record 18

19 1 Martin O’Malley became the Commissioner of Social Security on December 20, 20 2023. Pursuant to Rule 25(d) of the Rules of Civil Procedure, Martin O’Malley is 21 substituted for Kilolo Kijakazi as the Defendant in this suit. 1 and the parties’ briefing, is fully informed. For the reasons discussed below, 2 Plaintiff’s brief requesting an award of benefits, ECF No. 9, is denied, and 3 Defendant’s brief requesting remand, ECF No. 15, is granted. 4 JURISDICTION

5 Plaintiff Jamie Marie V. 2 (Plaintiff), filed for disability insurance benefits 6 (DIB) on February 4, 2020, alleging an onset date of September 25, 2018.3 Tr. 238- 7 41. Benefits were denied initially, Tr. 165-67, and upon reconsideration, Tr. 173-75.

8 Plaintiff appeared at a hearing before an administrative law judge (ALJ) on March 9 29, 2022. Tr. 75-98. On April 8, 2022, the ALJ issued an unfavorable decision, Tr. 10 14-36, and the Appeals Council denied review, Tr. 1-6. The matter is now before 11 this Court pursuant to 42 U.S.C. § 405(g).

12 13 14

15 2 The court identifies a plaintiff in a social security case only by the first name and 16 last initial in order to protect privacy. See Local Civil Rule 5.2(c). 17 3 Plaintiff previously filed Title II and Title XVI applications and a different ALJ 18 made an unfavorable decision on September 27, 2018. Tr. 99-121. The ALJ in

19 this case declined to reopen the prior decision. Tr. 17. As such, the period at issue 20 in this case begins on September 28, 2018, the day after the date of the prior 21 decision. Tr. 17. 1 BACKGROUND 2 The facts of the case are set forth in the administrative hearings and 3 transcripts, the ALJ’s decision, and the briefs of Plaintiff and the Commissioner, and 4 are therefore only summarized here.

5 Plaintiff was born in 1985 and was 36 years old on her date last insured. Tr. 6 30. She has work experience at a pet boarding facility and as a teacher’s aide. Tr. 7 90, 93. Plaintiff testified that she cannot work due to irritable bowel syndrome (IBS)

8 and colitis, severe pain in her back, and migraines. Tr. 81. She testified that she 9 needs to use the restroom from six to eight times in an eight-hour window. Tr. 82. 10 She has abdominal cramping. Tr. 82. Her back pain is in her sacroiliac (SI) joint. 11 Tr. 83. She has a migraine every couple of days. Tr. 86. A typical migraine lasts

12 anywhere from four hours to all day. Tr. 85. Plaintiff also testified she has 13 depression and anxiety. Tr. 88. She has been treated for borderline personality 14 disorder. Tr. 89.

15 STANDARD OF REVIEW 16 A district court’s review of a final decision of the Commissioner of Social 17 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 18 limited; the Commissioner’s decision will be disturbed “only if it is not supported by

19 substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 20 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a reasonable 21 mind might accept as adequate to support a conclusion.” Id. at 1159 (quotation and 1 citation omitted). Stated differently, substantial evidence equates to “more than a 2 mere scintilla[,] but less than a preponderance.” Id. (quotation and citation omitted). 3 In determining whether the standard has been satisfied, a reviewing court must 4 consider the entire record as a whole rather than searching for supporting evidence in

5 isolation. Id. 6 In reviewing a denial of benefits, a district court may not substitute its 7 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 1156

8 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one 9 rational interpretation, [the court] must uphold the ALJ’s findings if they are 10 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 11 F.3d 1104, 1111 (9th Cir. 2012). Further, a district court “may not reverse an ALJ’s

12 decision on account of an error that is harmless.” Id. An error is harmless “where it 13 is inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1115 14 (quotation and citation omitted). The party appealing the ALJ’s decision generally

15 bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 16 396, 409-10 (2009). 17 FIVE-STEP EVALUATION PROCESS 18 A claimant must satisfy two conditions to be considered “disabled” within the

19 meaning of the Social Security Act. First, the claimant must be “unable to engage in 20 any substantial gainful activity by reason of any medically determinable physical or 21 mental impairment which can be expected to result in death or which has lasted or 1 can be expected to last for a continuous period of not less than twelve months.” 42 2 U.S.C. §§ 423(d)(1)(A). Second, the claimant’s impairment must be “of such 3 severity that he is not only unable to do his previous work[,] but cannot, considering 4 his age, education, and work experience, engage in any other kind of substantial

5 gainful work which exists in the national economy.” 42 U.S.C. § 423(d)(2)(A). 6 The Commissioner has established a five-step sequential analysis to determine 7 whether a claimant satisfies the above criteria. See 20 C.F.R. § 404.1520(a)(4)(i)-

8 (v). At step one, the Commissioner considers the claimant’s work activity. 20 9 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in “substantial gainful 10 activity,” the Commissioner must find that the claimant is not disabled. 20 C.F.R. § 11 404.1520(b).

12 If the claimant is not engaged in substantial gainful activity, the analysis 13 proceeds to step two. At this step, the Commissioner considers the severity of the 14 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers from

15 “any impairment or combination of impairments which significantly limits [his or 16 her] physical or mental ability to do basic work activities,” the analysis proceeds to 17 step three. 20 C.F.R. § 404.1520(c).

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Vankeulen v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vankeulen-v-omalley-waed-2024.