Andrew Jauregui v. Carolyn W. Colvin, 2:16-cv-03959

Plaintiff Andrew Jauregui applied for DIB and SSI alleging disability from December 1, 2009; initial ALJ denied benefits in 2012; Appeals Council remanded for further development.
On remand a second ALJ (Everstine) held a hearing in April 2015 and again denied benefits, finding Jauregui capable of the full range of medium work.
Treating physician Shelly Heidelbaugh, M.D., treated Jauregui (Mar 2011–Jul 2012) and completed questionaires indicating severe functional limits (e.g., sitting/standing <2 hours/day, need to lie down 3–4 hours/day, no lifting, frequent absences).
The ALJ gave minimal to no weight to Dr. Heidelbaugh’s opinions, stating they were not well supported and inconsistent with the medical record, but did not identify specific conflicting evidence.
The Appeals Council denied review; district court reviewed and found the ALJ failed to provide clear and convincing reasons for discounting the uncontradicted treating opinion.
Court reversed and remanded for further administrative proceedings because the ALJ’s reasons were legally insufficient and further development could remedy errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the ALJ properly reject the treating physician’s opinion?	Dr. Heidelbaugh’s opinion should have been credited or given controlling weight; ALJ lacked clear and convincing reasons to reject it.	ALJ permissibly discounted the opinion as unsupported and inconsistent with the record.	Court: ALJ failed to state clear and convincing reasons; discounting was improper without specific conflicting evidence.
Standard of review for treating opinions	Treating opinion uncontradicted — requires clear and convincing reasons to reject.	ALJ relied on record inconsistency to discount opinion.	Court applied Ninth Circuit standards and found ALJ’s rationale conclusory and insufficient.
Remedy — remand for benefits vs. further proceedings	Jauregui argued errors mandate remand and possibly benefits.	Commissioner urged affirmance or remand without ordering benefits.	Court remanded for further administrative proceedings rather than awarding benefits.
Consideration of treating relationship factors	ALJ failed to address factors (length, frequency, supportability) required by regulation.	Commissioner contended ALJ implicitly considered record weight.	Court found ALJ did not analyze required factors and this omission was legal error.

Batson v. Comm'r of Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (treating physician rule and weight principles)
Magallanes v. Bowen, 881 F.2d 747 (9th Cir. 1989) (standards for evaluating medical opinions)
Holohan v. Massanari, 246 F.3d 1195 (9th Cir. 2001) (hierarchy of physician opinion weight)
Lester v. Chater, 81 F.3d 821 (9th Cir. 1995) (weight for treating/examining opinions)
Trevizo v. Berryhill, 871 F.3d 664 (9th Cir. 2017) (requiring clear and convincing reasons to reject uncontradicted treating opinions)
Orn v. Astrue, 495 F.3d 625 (9th Cir. 2007) (ALJ must give specific and legitimate reasons for rejecting contradicted opinions)
Carmickle v. Comm'r, 533 F.3d 1155 (9th Cir. 2008) (standards for rejecting medical opinions)
Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (opinion may be discounted if inadequately supported by clinical findings)
Rollins v. Massanari, 261 F.3d 853 (9th Cir. 2001) (ALJ may reject implausible treating opinions unsupported by findings)
Embrey v. Bowen, 849 F.2d 418 (9th Cir. 1988) (treating physicians’ conclusions entitled to substantial weight)
Harman v. Apfel, 211 F.3d 1172 (9th Cir. 2000) (remand for further proceedings vs. immediate benefits)
McLeod v. Astrue, 640 F.3d 881 (9th Cir. 2011) (remand appropriate when further administrative review could remedy errors)
Burrell v. Colvin, 775 F.3d 1133 (9th Cir. 2014) (serious doubt about disability supports further proceedings)