Darrell Dewey v. Andrew M. Saul, 2:19-cv-08002

Plaintiff Darrell D. applied for disability insurance benefits alleging neck, left-shoulder, back pain, paresthesia and grip loss with an alleged onset of February 1, 2014; last worked in 2013.
Administrative record documents torn rotator cuff with prior surgery, cervical degenerative disc disease, MRI findings, conservative treatment (medication, physical therapy), and reported partial improvement.
At hearing the ALJ found severe impairments: cervical degenerative disc disease and left-shoulder osteoarthritis/tendonitis, and assessed an RFC for a reduced range of light work with specific upper-extremity and postural limits.
The ALJ concluded claimant could not perform past relevant work but had transferable skills to sedentary, skilled occupations and therefore was not disabled.
The sole issue on appeal was whether the ALJ improperly rejected claimant’s testimony about pain and functional limitations.
The district court affirmed, finding the ALJ gave specific, clear and convincing reasons supported by substantial evidence (inconsistency with objective findings and reported activities; conservative/sparse treatment and symptom response); no malingering was found.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ improperly rejected claimant’s symptom testimony about pain and limitations	ALJ improperly discounted testimony based only on daily activities and conservative/sparse treatment, which Plaintiff says are inadequate reasons to discredit his allegations	ALJ permissibly relied on inconsistencies between testimony and medical records, claimant’s reported daily activities, limited treatment and documented symptom improvement; no finding of malingering	Court held ALJ did not err: provided specific, clear and convincing reasons supported by substantial evidence (objective inconsistency, daily activities, conservative treatment/response) and affirmed nondisability

Brown-Hunter v. Colvin, 806 F.3d 487 (9th Cir. 2015) (ALJ must identify which testimony is not credible and give clear and convincing reasons)
Bunnell v. Sullivan, 947 F.2d 341 (9th Cir. 1991) (medical findings need not fully corroborate alleged pain; establishes standard for symptom claims)
Benton ex rel. Benton v. Barnhart, 331 F.3d 1030 (9th Cir. 2003) (claimant must produce objective evidence of impairment that could produce symptoms; then ALJ must give clear and convincing reasons to reject testimony)
Thomas v. Barnhart, 278 F.3d 948 (9th Cir. 2002) (factors ALJ may consider in credibility analysis, including daily activities and inconsistencies)
Rollins v. Massanari, 261 F.3d 853 (9th Cir. 2001) (objective medical evidence is a relevant factor though not sole basis for discounting pain testimony)
Warre v. Comm’r, 439 F.3d 1001 (9th Cir. 2006) (impairments controlled effectively with medication are not disabling)
Parra v. Astrue, 481 F.3d 742 (9th Cir. 2007) (conservative treatment may justify discounting severity allegations)
Chaudhry v. Astrue, 688 F.3d 661 (9th Cir. 2012) (ALJ’s reasonable interpretations of medical record should not be second-guessed)
Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (ALJ satisfies substantial-evidence requirement by a detailed and thorough summary of facts and conflicting clinical evidence)