Chris C. v. Commissioner
- Thomas Hixson
- 3:25-cv-04134
- U.S. District Court · Northern District of California
- 7
In Chris C. v. SSA Commissioner, Judge Hixson denied Chris C.’s motion and granted the Commissioner’s cross-motion regarding disability benefits.
Chris C.’s disability-benefits claim was not reversed; the Commissioner prevailed on the cross-motion, and the case was ordered to be terminated after entry of a separate judgment.
What happened
In Chris C. v. SSA Commissioner, Chris C. asked the court to reverse the Social Security Administration’s denial of his disability-benefits claim. The Commissioner asked the court to affirm that denial.
Chris C. argued that a newer rule, which shortened the period for considering past relevant work from 15 years to five years, should have been applied because the Appeals Council denied review after the rule took effect. The court disagreed, explaining that the relevant decision date was the Administrative Law Judge’s April 23, 2024 decision, when the 15-year rule applied. Chris C.’s technical-writer work ended in July 2019, so it fell within that 15-year period.
Judge Hixson denied Chris C.’s motion for summary judgment and granted the Commissioner’s cross-motion. The court stated that it would enter a separate judgment and that the Clerk would then terminate the case.
The detailed version
- Chris C. v. Commissioner · No. 3:25-cv-04134
- Thomas Hixson
- Dec. 31, 2025
Background
Chris C. sought judicial review under 42 U.S.C. § 405(g) of the Social Security Administration’s denial of his claims for disability benefits under Titles II and XVI of the Social Security Act. An Administrative Law Judge held a hearing and issued an unfavorable decision on April 23, 2024. The Appeals Council denied review on March 14, 2025.
The Administrative Law Judge found that Chris C. had not engaged in substantial gainful activity since July 30, 2019, had several severe impairments, and did not have an impairment meeting the agency’s listed requirements. The Judge determined that Chris C. had the residual functional capacity—the most he could still do despite his limitations—to perform less than the full range of sedentary work. The Judge concluded that Chris C. could perform his past relevant work as a technical writer and therefore was not disabled.
Issue
Chris C. raised one issue: whether the Appeals Council erred by failing to apply Social Security Ruling 24-2p. That ruling shortened the period for considering past relevant work from 15 years to five years. Chris C. argued that because he stopped working as a technical writer in July 2019 and the Appeals Council denied review in March 2025, his technical-writer work was too remote to qualify as past relevant work under the five-year period.
Court’s analysis
The court explained that Social Security Ruling 24-2p applies prospectively to claims newly filed and pending beginning June 22, 2024. The agency’s guidance states that federal courts review final decisions using the rules in effect when the agency issued those decisions. The court also relied on Ninth Circuit authority holding that, when the Appeals Council denies review, the relevant adjudication date for determining past relevant work is the Administrative Law Judge’s decision date.
Because the Administrative Law Judge issued the decision on April 23, 2024, the 15-year rule applied. Chris C.’s technical-writer work ended in July 2019, so it was within the applicable 15-year period. The court therefore concluded that the Administrative Law Judge did not err by treating that work as past relevant work. The court also noted that, even if the five-year rule applied, Chris C.’s work through July 2019 would still have been within five years of April 23, 2024.
Disposition
The court DENIES Plaintiff’s motion for summary judgment and GRANTS Defendant’s cross-motion. The court ordered that a separate judgment be entered, after which the Clerk of Court would terminate the case.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.