Background

• Daniels, a plaintiff in the Central District of California, challenges the SSA Commissioner Colvin's denial of disability benefits.
• An Administrative Record and Joint Stipulation were filed; the matter proceeded before a Magistrate Judge per the Case Management Order.
• The disputed issue is whether Daniels’ left-hand injury, specifically a left ring finger flexor tendon injury, is a severe impairment at step two and whether the record was adequately developed.
• The August 2010 treatment for a left ring finger injury showed tendon injury with limited motion and recommended surgical repair.
• In January 2011, Dr. Rahman opined contractures and functional limits in the left hand, evidence the impairment exceeds minimal severity; the ALJ failed to recontact or adequately develop the record.
• The court remands for further proceedings to properly evaluate the left-hand impairment and to supplement the medical record.

Issues

Key Cases Cited

• Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (step-two de minimis screening; minimal impact on work ability)
• Webb v. Barnhart, 433 F.3d 683 (9th Cir. 2005) (severity determination must be supported by substantial evidence)
• Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (ALJ must set forth reasoned explanations for rejecting treating physician's opinions)
• Embrey v. Bowen, 849 F.2d 418 (9th Cir. 1988) ( require proper explanation for conflicting medical opinions)
• Lester v. Chater, 81 F.3d 821 (9th Cir. 1996) (specific and legitimate reasons needed to discount medical opinions)
• Tonapetyan v. Halter, 242 F.3d 1144 (9th Cir. 2001) (duty to develop record; obtain clarifications when necessary)
• Orn v. Astrue, 495 F.3d 625 (9th Cir. 2007) (independent clinical findings can constitute substantial evidence)
• INS v. Ventura, 537 U.S. 12 (2002) (remand when record incomplete pending further investigation)