Angel R Trevino v. Michael J Astrue, 2:12-cv-07740

Plaintiff Angel R. Trevino challenged the Commissioner of Social Security's denial of disability benefits in 2012 before a United States Magistrate Judge.
ALJ's July 29, 2011 decision found Trevino not disabled as of that date, with severe impairments including bipolar disorder and polysubstance dependence in partial remission.
RFC allowed a full range of work at all exertional levels but limited Trevino to simple, repetitive tasks with only occasional interaction with others; no past relevant work found.
Administrative record notes Trevino claimed onset around 1995 (later amended to 2009) with depression, anxiety, ADD, and ADHD; relevant hearings occurred July 11, 2011.
Appeals Council denied review; Trevino and Commissioner file cross-motions for summary judgment, which the court submitted without oral argument.
The court remanded the case for further proceedings, reversing the Commissioner’s decision due to errors in evaluating Trevino's credibility and lay witness evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the ALJ err in evaluating Trevino's credibility?	Trevino's credibility was not properly supported by specific, clear, and convincing reasons.	Any perceived inconsistencies were adequately explained by the record and conventional credibility factors.	Remand warranted for proper credibility assessment
Did the ALJ properly consider lay testimony from Trevino's fiancée?	Fiancée's lay observations corroborate Trevino's symptoms and were not adequately addressed.	Lay testimony was implicitly encompassed by credibility findings and not misapplied.	Remand warranted for proper consideration of lay testimony

Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (sequential evaluation framework and burden allocation)
Stout v. Commissioner, 454 F.3d 1050 (9th Cir. 2006) (five-step process and substantial evidence standard guidance)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (two-step credibility analysis for symptoms)
Greger v. Barnhart, 464 F.3d 968 (9th Cir. 2006) (requirement to identify credible testimonial evidence)
Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (lack of objective evidence is a factor in credibility but not sole basis)
Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (substantial evidence standard and credibility weighing)
Tonapetyan v. Halter, 242 F.3d 1144 (9th Cir. 2001) (ordinary techniques of credibility evaluation)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (adequacy of treatment-related credibility reasoning)
Connett v. Barnhart, 340 F.3d 871 (9th Cir. 2003) (remand appropriate where error is not harmless)
Regennitter v. Commissioner, 166 F.3d 1294 (9th Cir. 1999) (lay testimony is important evidence)