Vazquez v. Kijakazi

CourtDistrict Court, S.D. California
DecidedAugust 18, 2022
Docket3:20-cv-02014
StatusUnknown

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

Bluebook
Vazquez v. Kijakazi, (S.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 RAUL. V., Case No.: 20-cv-2014-BGS

12 Plaintiff, ORDER ON JOINT MOTION FOR 13 v. JUDICIAL REVIEW

14 KILOLO KIJAKAZI, Acting Commissioner of Social Security,1 [ECF 19] 15 Defendant. 16 17 18 I. INTRODUCTION 19 Plaintiff Raul V. (“Plaintiff”) filed a Complaint seeking judicial review of the 20 Commissioner of the Social Security Administration’s (“Commissioner” or “Defendant”) 21 denial of disability insurance benefits under the Social Security Act, (ECF 1), and the 22 Commissioner has filed the Administrative Record. (ECF 15.) 23 Pursuant to the Court’s Order, the parties have filed a Joint Motion for Judicial 24 Review. (ECF 16 (Court’s briefing Order); ECF 19 (Joint Motion).) Plaintiff seeks 25

26 27 1 Kilolo Kijakazi became Acting Commissioner of Social Security on July 9, 2021 and is therefore substituted for Andrew Saul as Defendant. See 42 U.S.C. § 405(g); Fed. R. Civ. 28 1 reversal of the final decision denying benefits and an order for the payment of benefits or, 2 in the alternative that the Court remand the case for further administrative proceedings. 3 (ECF 19 at 5-19, 26-39, 53 (Plaintiff’s positions); ECF 19 at 19-26, 39-54 (Defendant’s 4 positions).) Plaintiff argues the Administrative Law Judge (“ALJ”) erred in rejecting 5 Plaintiff’s symptom testimony. (Id. at 5-19.) Plaintiff also argues the case must be 6 remanded for a new hearing because the final decision of the Commissioner arose from 7 an unconstitutional administrative process. (Id. at 26-39.) Defendant argues that the 8 ALJ’s decision provided valid reasons for discounting Plaintiff’s subjective complaints 9 and Plaintiff’s separation of powers argument related to the appointment of the 10 Commissioner and ALJ does not entitled him to a rehearing of his claim. (Id. at 19-26, 11 39-54.) 12 After careful consideration of the parties’ arguments, the administrative record and 13 the applicable law and for the reasons discussed below, the Court finds Plaintiff is entitled 14 to summary judgment and remand of the case to the Social Security Administration for 15 further administrative proceedings. 16 II. PROCEDURAL HISTORY 17 The following procedural history is drawn largely from the parties’ joint summary 18 of the procedural history of the case. (ECF 19 at 2.) Plaintiff’s application for disability 19 benefits was filed on February 20, 2018, alleging disability commencing on March 3, 20 2015. (AR 151-153.) The claim was denied initially on July 13, 2018 and denied on 21 reconsideration on September 26, 2018. (AR 89-94.) At Plaintiff’s request, a hearing was 22 held before an ALJ on October 23, 2019. (AR 13-42 (hearing transcript), 96-97 (request 23 for hearing), 114-136 (notices related to hearing).) The ALJ issued an unfavorable 24 decision on November 26, 2019. (AR 67-84.) Plaintiff sought and obtained Appeals 25 Council review. (AR 143-150.) On August 24, 2020, the Appeals Council issued an 26 unfavorable decision. (AR 1-9.) 27 28 1 III. APPEALS COUNCIL / ALJ DECISION 2 The Appeals Council adopted the ALJ’s decision that Plaintiff was not disabled 3 and found Plaintiff was not disabled for the period of January 1, 2018 to December 2, 4 2019.2 (AR 4-7.)3 The parties provided a joint summary of the decision and the 5 application of the five-step sequential evaluation process. (ECF 19 at 3-4.) The Court 6 addresses relevant portions of the ALJ decision below in more detail but notes here that 7 at step two the ALJ found Plaintiff had the following medically determinable severe 8 impairments: “degenerative disc disease of the lumbar spine; retrolisthesis; lumbar 9 radiculopathy; chronic pain disorder; right-sided sciatica; bipolar mood disorder; 10 generalized anxiety disorder; major depressive disorder; panic disorder; and post- 11 traumatic stress disorder (“PTSD”)).” (AR 73; AR 6.) The ALJ found Plaintiff did not 12 meet a listing at step three. (AR 74, AR 6.) The ALJ then assessed the following residual 13 functional capacity (“RFC”): 14 After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as 15 defined in 20 C.F.R. § 404.1567(b) except the claimant is limited to 16 occasional climbing of ramps/stairs, occasional climbing of ladders/ropes/scaffolds, and occasional balancing, stooping, kneeling, 17 crouching and crawling. In addition, the claimant is limited to 18 understanding, remembering, and carrying out simple, routine tasks, only occasional interaction with the general public, only occasional work-related, 19 non-personal, non-social interaction with coworkers and supervisors, and 20 can perform jobs requiring only simple work-related decisions.

21 (AR 6, 76.) 22 The ALJ determined at step four that Plaintiff could not do his past relevant 23 work as tune up mechanic or that kind of work. (AR 6, 79-80.) At step five, the 24 25 26 2 Plaintiff initially claimed an onset date of March 3, 2015, but amended his onset date to 27 January 1, 2018 at his hearing before the ALJ. (AR 40 (hearing transcript); AR 4 (Appeals Council Decision noting change).) 28 1 ALJ found Plaintiff retained the residual functional capacity to perform the work 2 of marker, assembler, and housekeeper cleaner and denied disability benefits. (AR 3 6-7, 80-81.) 4 IV. DISCUSSION 5 The parties’ raise the following two issues: (1) whether the ALJ erred in rejecting 6 Plaintiff’s testimony regarding his symptoms; and (2) whether the final decision arises 7 from an unconstitutional administrative process that requires remand for a new hearing. 8 (ECF 19.) For the reasons discussed below, the Court finds the ALJ erred in his 9 consideration of Plaintiff’s symptom testimony and remand is required on this basis. 10 Additionally, although the Court need not reach the second issue because the case is 11 already being remanded, the Court finds Plaintiff would not be entitled to a new hearing 12 based on the administrative process. The Court first addresses the ALJ’s treatment of 13 Plaintiff’s testimony regarding his symptoms. 14 A. Plaintiff’s Symptom Testimony 15 1. Parties’ Positions 16 Plaintiff argues the ALJ failed to provide any rationale for rejecting Plaintiff’s 17 symptom testimony. (ECF 19 at 8-9.) In particular, Plaintiff asserts that the ALJ erred in 18 providing only a routine and conclusory statement vaguely concluding Plaintiff’s 19 allegations regarding the severity of his symptoms were not consistent with the objective 20 evidence. (Id. at 9-10.) Plaintiff argues this was deficient because an ALJ is not permitted 21 to reject subjective pain testimony solely on the basis of objective medical evidence, and 22 the objective medical evidence supports the severity of his symptoms. (Id. at 9-13.) 23 Additionally, Plaintiff asserts that the decision lacks any connection between any portion 24 of Plaintiff’s testimony and portions of the record supporting the ALJ’s decision to reject 25 the testimony. (Id. at 10-12.) Plaintiff also argues the ALJ erred in relying on Plaintiff’s 26 activities of daily living to reject Plaintiff’s testimony because the sporadic activities 27 described do not contradict his testimony or demonstrate he can spend a substantial part 28 of the day doing activities transferable to a full-time work setting. (Id. at 13-18.) 1 Defendant counters that the ALJ properly evaluated Plaintiff’s subjective 2 complaints and found “them inconsistent with the objective medical evidence, Plaintiff’s 3 treatment history, and his admitted activities, including part-time work.” (Id.

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Vazquez v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vazquez-v-kijakazi-casd-2022.