D. Idaho Affirms Social Security Disability Denial

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April 24, 2026 Get Citation Alerts Download PDF Add Note

Howard William P. v. Commissioner of Social Security

District Court, D. Idaho

• Citations: None known
• Docket Number: 1:24-cv-00477

• Precedential Status: Unknown Status

• Opinion

• Authorities (3)

• Cited By (0)

• Summaries (0)

• Similar Cases (0)

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Trial Court Document

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

HOWARD WILLIAM P.,
Case No. 1:24-cv-00477-AKB-DKG
Plaintiff,
MEMORANDUM DECISION AND
v. ORDER ADOPTING REPORT AND
RECOMMENDATION
COMMISSIONER OF SOCIAL
SECURITY,

Defendant.

Pending before the Court is Plaintiff’s Petition for Review of the Commissioner of Social
Security’s denial of Disability Insurance Benefits (Dkt. 1). Having reviewed the record and the
parties’ submissions, the Court finds that the facts and legal arguments are adequately presented
and that oral argument would not significantly aid the decisional process. Dist. Idaho Loc. Civ.
R. 7.1(d)(1)(B); see also Fed. R. Civ. P. 78(b). For the reasons explained below, the Court adopts
the Report and Recommendation of the United States Magistrate Court (Dkt. 22), overrules
Plaintiff’s objections (Dkt. 23), and affirms the ALJ’s decision.
I. BACKGROUND
Plaintiff filed an application for Disability Insurance Benefits on March 15, 2022,
originally alleging disability beginning September 6, 2021 (Dkt. 22 at 2). He was sixty-two years
old on the amended onset date and has some college education with past relevant work as an
engineering technician and a process engineer (id.). The ALJ found multiple severe impairments
and determined that none of them, singly or in combination, met or equaled a listed impairment
(id. at 3).
The ALJ assessed a residual functional capacity (RFC) for light work with exertional,
postural, and environmental restrictions (Dkt. 10 at 27–28). The ALJ concluded that because
Plaintiff could perform past relevant work as a process engineer, he was not disabled (Dkt. 22 at
4). The ALJ ultimately concluded that Plaintiff was not disabled from September 6, 2021, through
February 28, 2024—the date of the decision (Dkt. 10 at 33).

After the Appeals Council denied review (Dkt. 1-1 at 2), Plaintiff sought judicial review in
this Court on October 10, 2024 (Dkt. 1). The case was referred to the Magistrate Court, who issued
a Report and Recommendation (R&R) on February 6, 2026, recommending the ALJ’s decision be
affirmed (Dkt. 22). Plaintiff filed objections on February 18 (Dkt. 23), and the Commissioner
responded on March 4 (Dkt. 24).
II. OBJECTIONS
Plaintiff raises two objections to the R&R. First, he argues that the Magistrate Court erred
in finding that the ALJ’s error in failing to comply with 20 C.F.R. § 404.1520c is harmless (Dkt. 23
at 2). Second, Plaintiff objects to the Magistrate Court’s finding that the ALJ adequately explained

the discrepancy between her contrary findings in this decision (id. at 3).
III. LEGAL STANDARD
The Court reviews de novo the portions of the R&R to which objections have been made. 28 U.S.C. § 636 (b)(1). The ALJ’s decision must be upheld if supported by substantial evidence
and free of legal error. 42 U.S.C. § 405 (g); Trevizo v. Berryhill, 871 F.3d 664, 674 (9th Cir. 2017).
Substantial evidence is more than a mere scintilla but less than a preponderance. Richardson v.
Perales, 402 U.S. 389, 401 (1971). Where evidence is susceptible to more than one rational
interpretation, the Court must defer to the ALJ’s interpretation. Batson v. Comm’r of Soc. Sec.
Admin., 359 F.3d 1190, 1193 (9th Cir. 2004).
IV. ANALYSIS
A. Stooping Restriction
Plaintiff objects to the Magistrate Court’s recommendation to uphold the ALJ’s decision
despite an inconsistency between the RFC and the opinion of Michael Spackman, M.D.M..S.,
which the ALJ found very persuasive, as it relates to stooping (Dkt. 23 at 2). He contends that the

Magistrate Court improperly relied on a lay interpretation of vocational evidence in concluding
that the error was harmless (id.).
The Court recognizes that the ALJ’s finding that Plaintiff can frequently stoop (Dkt. 10 at
27–28) is seemingly in conflict with Spackman’s opinion stated that Plaintiff’s postural activities
should be limited to “occasional” (id. at 1027). The Court agrees with the Magistrate Court’s
recommended finding that the ALJ erred by failing to articulate the reason for assessing an RFC
limitation for stooping that was both greater than and different from Spackman’s opinion. The
Magistrate Court, however, found that this error was harmless because the ALJ’s determination
that Plaintiff could return to his past relevant work as a process engineer—which is defined as light
work with no stooping requirement—is consistent with Spackman’s opinion that Plaintiff can

occasionally stoop (Dkt. 22 at 8–10). Thus, even if the ALJ adopted Spackman’s opinion of
occasional stooping, the decision still supports the ALJ’s ultimate disability determination that
Plaintiff could perform his past relevant work as a process engineer.
Plaintiff maintains that the ALJ’s error was not harmless because the description in the
Dictionary of Occupational Titles (DOT) states that the work of a process engineer does not require
stooping “is at odds with Social Security Rule 83-14” (Dkt. 23 at 2). He explains that the “ruling
clarifies that, in order to perform substantially all of the exertional requirements of most sedentary
and light jobs, a person would need to be able to stoop, at least, occasionally” (id.). He then
characterizes the Magistrate Court’s interpretation of the DOT job description as a “lay
interpretation of a vocational issue which was not addressed during the hearing because the ALJ
omitted a key restriction from the RFC and from the hypothetical which the VE was asked to
assume” (id.). Thus, according to Plaintiff, a vocational expert is required to interpret DOT
012.167-042 (id.).
The Court disagrees. As noted by the Commissioner, the Magistrate Court merely read the

process engineer description contained in DOT 012.167-042, which states, “Stooping: Not Present
- Activity or condition does not exist.” And contrary to Plaintiff’s assertion, SSR 83-14 provides
that “most light jobs” require the worker “to do occasional bending of the stooping type,” not all
light jobs. Nothing in SSR 83-14 precludes the more specific description in the process engineer
DOT entry from clarifying the physical requirements for that particular job. Accordingly, SSR 83-
14 and DOT 012.167-042 are not in conflict. Nor is a vocational expert required to interpret this
information. See 20 C.F.R. § 404.1566 (d)(1) (providing for administrative notice of job
information available in the DOT). The Court, therefore, overrules Plaintiff’s first objection.
B. Mental RFC Assessment
Plaintiff next objects to the Magistrate Court’s recommended finding that the ALJ

adequately explained the discrepancy between her findings at step two and the mental RFC
assessment (Dkt. 23 at 3). Plaintiff argues that the Magistrate Court erred in finding that the ALJ
reconciled her mental findings under the paragraph “B” criteria at step two of the sequential
evaluation process with the limitations assessed in the mental RFC by “craft[ing] a logical bridge
which the ALJ did not build” (id.). Plaintiff posits that the Court should reject the Magistrate
Court’s finding of no error in the ALJ’s failure to explain the discrepancy between the mental
limitations found at step two and the RFC, which contains no mental limitations (id. at 4).
The Court disagrees. The ALJ found that Plaintiff had mild limitations in (1) concentrating,
persisting, or maintaining pace, and (2) adapting or managing oneself (Dkt. 10 at 25–26). As the
Magistrate Court explained, the ALJ’s RFC assessment included discussion of Plaintiff’s
handwritten report, hearing testimony, the third-party report of Plaintiff’s spouse, treatment
records, and medical opinion evidence (Dkt. 22 at 13–15) (citing Dkt. 10 at 28–32)). Though the
ALJ did not repeat her paragraph B findings in the RFC discussion, she discussed many of the
same records underlying those findings, including, at times, conflicting reports (see, e.g., Dkt. 10

at 30 (noting “[Plaintiff’s] statements about the intensity, persistence, and limiting effects of [his]
symptoms,” are “inconsistent with his reported daily activities and his spouse’s report of his
volunteer work as prison chaplain”)). The ALJ then considered the medical opinion evidence from
Spackman and Scott Culpepper, M.D., finding Spackman’s opinion very persuasive and
Culpepper’s not persuasive (id. at 31). She also evaluated the two prior administrative medical
findings, which she found partially persuasive and persuasive, both of which concluded that
Plaintiff had a mild limitation but could perform his past relevant work (id. at 31–32).
Contrary to Plaintiff’s assertions, the Magistrate Court’s findings on the ALJ’s analysis
was not based on post hoc rationalizations or attempts to infer conclusions the ALJ did not

articulate. Rather, the Magistrate Court examined the actual reasons the ALJ provided for her RFC
findings. On this record, the Court finds no inconsistency between the mental limitations identified
at step two and absence of corresponding restrictions in the RFC. The Court agrees with the
Magistrate Court’s assessment that the ALJ properly considered the totality of the evidence in
setting the RFC, including Plaintiff’s mental limitations, and explained the reasoning for the RFC
assigned.
Because the ALJ reasonably resolved the evidentiary conflicts and grounded the analysis
in the longitudinal record, the Court finds that substantial evidence supports the mental RFC
determination. The Magistrate Court correctly concluded that no legal error occurred, and the
Court overrules Plaintiff's second objection.
Vv. CONCLUSION
Having conducted a de novo review, the Court finds that the ALJ’s decision is supported
by substantial evidence and is free of legal error. The Magistrate Court’s Report and
Recommendation (Dkt. 22) is adopted in full.
VI. ORDER
IT IS ORDERED:
1. Plaintiff's Objections (Dkt. 23) are OVERRULED.
2. The Report and Recommendation (Dkt. 22) is ADOPTED.
3. The ALJ’s decision denying benefits is AFFIRMED.
4. This action is DISMISSED in its entirety with prejudice.

KS DATED: April 24, 2026

. Ysy Amanda K. Brailsford
SRICT U.S. District Court Judge

MEMORANDUM DECISION AND ORDER ADOPTING REPORT AND RECOMMENDATION — 6