Wasson v. Kijakazi

CourtDistrict Court, D. Nevada
DecidedOctober 25, 2022
Docket2:22-cv-00484
StatusUnknown

This text of Wasson v. Kijakazi (Wasson v. Kijakazi) 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
Wasson v. Kijakazi, (D. Nev. 2022).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 6 NICOLE ELIZABETH WASSON, Case No. 2:22-cv-00484-NJK

7 Plaintiff(s), ORDER 8 v. 9 KILOLO KIJAKAZI, 10 Defendant(s). 11 This case involves judicial review of administrative action by the Commissioner of Social 12 Security (“Commissioner”) denying Plaintiff’s application for disability insurance benefits 13 pursuant to Title II and supplemental security income pursuant to Title XVI of the Social Security 14 Act. Currently before the Court is Plaintiff’s motion to reverse or remand. Docket No. 19. The 15 Commissioner filed a response and cross-motion to affirm. Docket Nos. 20, 21. Plaintiff filed a 16 reply to the Commissioner’s response. Docket No. 22. 17 I. STANDARDS 18 A. Disability Evaluation Process 19 The standard for determining disability is whether a social security claimant has an 20 “inability to engage in any substantial gainful activity by reason of any medically determinable 21 physical or mental impairment which can be expected to last for a continuous period of not less 22 than 12 months.” 42 U.S.C. § 423(d)(1)(A); see also 42 U.S.C. § 1382c(3)(A). That determination 23 is made by following a five-step sequential evaluation process. Bowen v. Yuckert, 482 U.S. 137, 24 140 (1987) (citing 20 C.F.R. §§ 404.1520, 416.920). The first step addresses whether the claimant 25 is currently engaging in substantial gainful activity. 20 C.F.R. §§ 404.1520(b), 416.920(b).1 The 26 second step addresses whether the claimant has a medically determinable impairment that is severe 27 1 The five-step process is largely the same for both Title II and Title XVI claims. For a Title 28 II claim, however, a claimant must also meet insurance requirements. 20 C.F.R. § 404.130. 1 or a combination of impairments that significantly limits basic work activities. 20 C.F.R. §§ 2 404.1520(c), 416.920(c). The third step addresses whether the claimant’s impairments or 3 combination of impairments meet or medically equal the criteria of an impairment listed in 20 4 C.F.R. Part 404, Subpart P, Appendix 1. 20 C.F.R. §§ 404.1520(d), 404.1525, 404.1526, 5 416.920(d), 416.925, 416.926. There is then a determination of the claimant’s residual functional 6 capacity (“RFC”), which assesses the claimant’s ability to do physical and mental work-related 7 activities. 20 C.F.R. §§ 404.1520(e), 416.920(e). The fourth step addresses whether the claimant 8 has the residual functional capacity to perform past relevant work. 20 C.F.R. §§ 404.1520(f), 9 416.920(f). The fifth step addresses whether the claimant is able to do other work considering the 10 residual functional capacity, age, education, and work experience. 20 C.F.R. §§ 404.1520(g), 11 416.920(g). 12 B. Judicial Review 13 After exhausting the administrative process, a claimant may seek judicial review of a 14 decision denying social security benefits. 42 U.S.C. § 405(g). The Court must uphold a decision 15 denying benefits if the proper legal standard was applied and there is substantial evidence in the 16 record as a whole to support the decision. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). 17 Substantial evidence is “more than a mere scintilla,” which equates to “such relevant evidence as 18 a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, ___ 19 U.S. ____, 139 S.Ct. 1148, 1154 (2019). “[T]he threshold for such evidentiary sufficiency is not 20 high.” Id. 21 II. BACKGROUND 22 A. Procedural History 23 On October 31, 2016, Plaintiff protectively filed an application for Social Security 24 Disability Insurance benefits pursuant to Title II of the Social Security Act.2 Administrative 25 2 There is disagreement between the parties as to when Plaintiff first filed for Social Security 26 benefits. Compare Docket No. 19 at 3 with Docket No. 20 at 2. Knowing the precise application date is exceptionally important here as Plaintiff’s October 31, 2016, application for benefits could 27 be read to preclude a protective filing date for her Title XVI application. A.R. 342 (“I do not want to file for SSI.”). Cf. Programs Operation Manual Systems GN 00204.020(D). This small 28 ambiguity in the record creates the potential for significant legal issues as the standards for the evaluation of medical evidence changed in the time between the filing of Plaintiff’s Title II 1 Record (“A.R.”) 342-343. Plaintiff alleged a disability starting on September 23, 2016. A.R. 342. 2 On February 14, 2018, Plaintiff filed an application for supplemental security income benefits 3 under Title XVI of the Social Security Act, A.R. 356, alleging a disability starting January 1, 2016, 4 A.R. 357. Plaintiff’s initial application was denied on April 12, 2017. A.R. 164. Plaintiff then 5 filed a request for reconsideration, A.R. 172, which was denied, A.R. 173-75. On September 21, 6 2017, Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”) regarding her 7 benefits determination. A.R. 179. ALJ Timothy Stueve held a hearing on August 14, 2019. A.R. 8 82-103. He issued a decision denying Plaintiff benefits on September 3, 2019. A.R. 132-45. 9 Plaintiff filed a request for review by the Appeals Council on October 30, 2019. A.R. 252- 10 54. In June 2020 the Appeals Council ordered Plaintiff’s case remanded for another hearing before 11 an ALJ. A.R. 157-63. The Council determined remand to be appropriate as a portion of the record 12 related to a different claimant and Plaintiff had submitted new evidence. A.R. 159-60. The remand 13 order directed the ALJ to retain a medical expert to opine on the nature and severity of Plaintiff’s 14 impairments. A.R. 160. 15 ALJ Cynthia Hoover conducted the subsequent hearing in January 2021. A.R. 54-81. At 16 that hearing, Dr. Julian Melamed testified as a medical expert, A.R. 53-65, and Elizabeth Brown- 17 Ramos testified as a vocational expert, A.R. 75-79. On March 17, 2021, ALJ Hoover issued a 18 decision again denying Plaintiff benefits. A.R. 15-34. 19 20

21 application and her Title XVI application. See, e.g., 20 C.F.R. §§ 404.1527, 404.1520c. However, the parties have not addressed this issue in their briefing. The regulations addressing treating a 22 Title II application as an oral inquiry for SSI benefits are silent on the issue of excluding an SSI protective date from such an application. 20 C.F.R. §§ 416.350, 416.345.

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Wasson v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wasson-v-kijakazi-nvd-2022.