Cody v. Commissioner of Social Security, 3:24-cv-05294

Plaintiff, Brian J. C., applied for Supplemental Security Income (SSI) and Disability Insurance Benefits (DIB) in 2014, alleging disability due to various mental health conditions and back pain.
Plaintiff's claims were denied at various administrative levels, including after multiple hearings before different Administrative Law Judges (ALJs) and reviews by both the District Court and Ninth Circuit.
The Ninth Circuit remanded the case for reconsideration under the Appointments Clause, leading to a new ALJ hearing in 2023, which again resulted in a finding of no disability.
Plaintiff alleged severe mental and physical impairments, primarily bipolar disorder, social anxiety disorder, major depressive disorder, PTSD, personality disorder, and back pain.
The ALJ applied the five-step disability evaluation process and found Plaintiff had severe mental impairments, but no severe physical impairment, and was capable of performing certain unskilled jobs existing in the national economy.
The District Court reviewed the final Commissioner decision for harmful legal error or lack of substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ’s evaluation of Plaintiff’s testimony	ALJ misevaluated, ignored abnormal findings, and activities did not show ability to work	ALJ properly discounted for inconsistencies, minimal treatment, ongoing job search, daily life	ALJ provided clear, convincing reasons; no error
Evaluation of lay witness testimony	ALJ failed to properly consider lay witness C.H.’s statements	ALJ had germane reasons, lay and Plaintiff’s testimony were similar, so same rationales applied	No error in lay witness evaluation
Step two physical impairment finding	ALJ failed to find severe physical impairment, ignored supporting evidence	ALJ properly found no severe impairment based on medical record and opinion evidence	No error; ALJ properly addressed at later steps
Evaluation of medical opinion evidence	ALJ erred in discounting treating/examining opinions, acted as own medical expert	ALJ provided specific, legitimate reasons for each contested opinion, supported by record	No error in medical evidence evaluation

Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (substantial evidence standard and court's review role in Social Security appeals)
Burrell v. Colvin, 775 F.3d 1133 (9th Cir. 2014) (clear and convincing reasons required for discounting claimant testimony)
Andrews v. Shalala, 53 F.3d 1035 (9th Cir. 1995) (ALJ’s role in evaluating symptom testimony and resolving medical conflicts)
Lester v. Chater, 81 F.3d 821 (9th Cir. 1996) (treating source rule and standards for discounting medical opinions)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (discounting opinions based on properly discredited self-reporting)
Rollins v. Massanari, 261 F.3d 853 (9th Cir. 2001) (objective evidence can be a factor in evaluating symptom severity)