Boh v. Commissioner of Social Security
2:23-cv-00198-EJY
| D. Nev. | Feb 16, 2024Background
- Ikelene Boh applied for Social Security disability benefits, alleging disability beginning January 1, 2016.
- Her applications were denied at the initial and reconsideration levels; the ALJ also found her not disabled after hearings in 2019 and 2022.
- The district court previously remanded the case for further proceedings due to the ALJ's failure to provide adequate reasons for rejecting medical opinions.
- On remand, a new ALJ again found Boh not disabled at step five, concluding she had several severe impairments but retained the RFC for light work with additional limitations.
- Boh challenged the second ALJ decision, particularly the rejection of opinions by her treating physician (Dr. Cruvant) and social worker (Ms. Villglobos).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ erred in rejecting Dr. Cruvant's treating opinion | ALJ failed to provide specific and legitimate reasons; opinion should be controlling | Dr. Cruvant's limitations were extreme and unsupported by medical evidence | No error; ALJ provided sufficient reasons |
| Whether the ALJ erred in rejecting Ms. Villglobos' social worker opinion | ALJ failed to build a logical bridge; opinion supported by record | Not an acceptable medical source; opinion inconsistent with treatment notes | No error; reasons for rejection were germane |
| Whether ALJ should have developed the record further | ALJ needed to obtain a more current medical opinion | No deficiency; ALJ's analysis adequate | No error; record was adequately developed |
| Whether ALJ's RFC finding was based on substantial evidence | Limitations not properly evaluated | RFC consistent with objective evidence | RFC finding supported by substantial evidence |
Key Cases Cited
- Batson v. Comm'r Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (outlining standard for substantial evidence and review of ALJ determinations)
- Ford v. Saul, 950 F.3d 1141 (9th Cir. 2020) (defining "substantial evidence" and review standards)
- Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (weight to be given to treating and non-treating medical opinions)
- Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (ALJ must set out detailed findings and explanations when rejecting treating physician opinions)
- Martinez v. Heckler, 807 F.2d 771 (9th Cir. 1986) (reviewing courts must weigh both supportive and detracting evidence)
- Andrews v. Shalala, 53 F.3d 1035 (9th Cir. 1995) (ALJ’s decision must be upheld if supported by a rational interpretation)