Whitten v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedJune 16, 2023
Docket2:21-cv-01132
StatusUnknown

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

Bluebook
Whitten v. Commissioner of Social Security Administration, (D. Ariz. 2023).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Tammy Whitten, No. CV-21-01132-PHX-GMS

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 16 Plaintiff challenges the dismissal of her October 2019 application for disability 17 insurance benefits under Title II of the Social Security Act (“the Act”). Having reviewed 18 the briefs and Administrative Record (Doc. 15, AR.), the Court finds it has no subject 19 matter jurisdiction to review the Commissioner’s October 23, 2020 Order of Dismissal. 20 (AR. at 27-31.) Accordingly, this action is dismissed. 21 I. PROCEDURAL HISTORY 22 Plaintiff filed an application for disability benefits in June 2014 alleging disability 23 beginning May 2013. (AR. at 387.) She was insured for Title II disability benefits until 24 June 30, 2017. (AR. at 389, 446.) The Commissioner denied this application at the initial 25 and reconsideration levels of administrative review, and Plaintiff timely requested a 26 hearing. (AR. at 387.) Administrative Law Judge (“ALJ”) Guy Fletcher presided over a 27 hearing on February 16, 2017, at which the Plaintiff and a vocational expert testified. (AR. 28 at 284-307.) Plaintiff was represented at this hearing. (AR. at 284.) The ALJ issued an 1 unfavorable decision on July 3, 2017. (AR. at 387-401.) He concluded Plaintiff had the 2 residual functional capacity (“RFC”) to perform her past relevant work and was not 3 disabled at step four. (AR. at 395.) Plaintiff timely appealed, but the Appeals Council 4 denied review in a letter dated May 22, 2018. (AR. at 308-10.) Plaintiff did not challenge 5 the final ALJ denial in federal court. 6 Plaintiff filed her current application in October 2019 alleging disability beginning 7 June 29, 2017 (AR. at 439-40)—one day before her insured status expired (AR. at 389). 8 The Commissioner denied Plaintiff’s claim at the initial level of administrative review on 9 the basis that her condition was not disabling through her date last insured (“DLI”). (AR. 10 at 402-06.) Plaintiff filed for reconsideration with the assistance of new counsel, but on 11 June 2, 2020, her request was denied on res judicata grounds. (AR. at 412-14.) The notice 12 explained, “Res judicata applies when the subsequent application presents no new facts or 13 issues from the ones considered in the prior decision.” (AR. at 412.) The notice further 14 explained that, if Plaintiff disagreed, she could request a hearing within 60 days, which 15 would be reviewed by an ALJ. (AR. at 412.) 16 Throughout the initial and reconsideration phases of this new application, the state 17 agency processing Plaintiff’s claim received new evidence from the previously-adjudicated 18 period ending on Plaintiff’s June 30, 2017 DLI. This evidence included additional 19 treatment notes from Plaintiff’s primary care providers at Mountain Park Health Center 20 dated from August 31, 2015 to February 21, 2020 (AR. at 906-926, 1017-1061, 1162- 21 1232); May 2016 and May 2017 notes from her treating neurologist, Dr. Kari Patterson 22 (AR. at 962-63); visits from Plaintiff’s treating podiatrists dated from May 2017 to May 23 2018 (AR. at 970-1009); and visits from her treating pain management provider, Dr. Otto 24 Uhrik, dated from June 2017 to May 2020 (AR. at 1089-1161, 1235-1345). These records 25 also included other evidence of Plaintiff’s treatment for other impairments throughout 2018 26 and 2019 (AR. at 928-54, 1062-1083) and an assessment form from her treating provider 27 (AR. at 1233-1234). 28 On July 29, 2020, the SSA sent Plaintiff a letter acknowledging her hearing request. 1 (AR. at 416-18.) The letter explained, among other things, that Plaintiff must inform and 2 submit to the ALJ all evidence known to her, that an ALJ would consider the issues and 3 the evidence, and that Plaintiff could see the evidence in her file upon request. (AR. at 4 417.) The letter stated a hearing would be scheduled. (AR. at 416.) 5 In a letter dated October 23, 2020, however, ALJ Paul Isherwood dismissed 6 Plaintiff’s request for a hearing on res judicata grounds. (AR. at 27-31.) ALJ Isherwood 7 found that none of the regulatory conditions justified reopening Plaintiff’s prior 8 application, and that “the previous decision remains final and binding.” (AR. at 30.) The 9 ALJ noted he had compared the evidence from the prior file to the evidence in the current 10 file, and that he found “no new and material evidence has been submitted and that there 11 has been no change in statute, regulation, ruling or legal precedent concerning the facts and 12 issues ruled upon in connection with the previously adjudicated period.” (AR. at 30.) 13 “Accordingly,” he reasoned, “the claimant’s rights on the same facts and on the same issues 14 are involved and the doctrine of res judicata applies.” (AR. at 31.) 15 Plaintiff then filed a Request for Review with the Social Security Appeals Council. 16 (AR. at 23-26.) With it, she submitted additional treatment records, including records of 17 additional visits with Dr. Patterson dating from August 2014 to September 2015 (AR. at 18 148-51), physical therapy notes from December 2016 to January 2017 (AR. at 244-52), 19 and a right shoulder operative report from May 2015 (AR. at 267-69). These records also 20 included updated primary care notes (AR. at 108-123), pain management notes (AR. at 57- 21 80), and an assessment form completed by Plaintiff’s treating pain management provider 22 (AR. at 203-204). In a letter dated April 30, 2021, the Appeal Council declined review. 23 (AR. at 1-2.) The Administrative Appeals Judge noted Plaintiff’s additional evidence had 24 been considered, but that did not show that different facts or issues were involved, it was 25 not relevant to the time period, or that it was previously considered in the prior 26 determination. (AR. at 2.) Plaintiff then commenced this civil action. (Doc. 1.) 27 II. ISSUES 28 Was there new material evidence sufficient to reopen Plaintiff’s claim, and is the 1 ALJ’s decision to deny reopening her claim based on res judicata reviewable? Does the 2 denial constitute “manifest injustice” or a denial of due process?. 3 III. DISCUSSION 4 Res judicata applies in administrative proceedings such as disability determinations, 5 although “less rigidly” than in judicial proceedings. Chavez v. Bowen, 844 F.2d 691, 693 6 (9th Cir. 1988). In disability determinations, ALJs may invoke res judicata to bar reopening 7 of a prior application for benefits concerning a previously adjudicated period of alleged 8 disability, or ALJs could apply it to bar benefits for a subsequent period under a new 9 application for benefits. Lester v. Chater, 81 F.3d 821, 827 (9th Cir. 1995), as amended 10 (Apr. 9, 1996). An ALJ’s determination that a claimant is not disabled creates a rebuttable 11 presumption of continuing non-disability as to any subsequent, non-adjudicated period, but 12 “[t]he Commissioner’s authority to apply res judicata to the period subsequent to a prior 13 determination is much more limited.” Id. To overcome this presumption, Plaintiff need 14 only show “changed circumstances,” such as a worsening of a pre-existing impairment, a 15 change in age category since the prior denial, or the existence of a new impairment not 16 previously considered. Lester, 81 F.3d at 827. 17 Still, “[t]he Commissioner may . . . apply res judicata to bar reconsideration of a 18 period with respect to which she has already made a determination, by declining to reopen 19 the prior application.” Id. (citing Krumpelman v. Heckler, 767 F.2d 586, 588 (9th 20 Cir.1985)).

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Whitten v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitten-v-commissioner-of-social-security-administration-azd-2023.