Emma Klein v. Nancy Berryhill, 16-16353

Emma Klein appealed the denial of Title II disability insurance benefits; Ninth Circuit affirmed.
ALJ found Klein not fully credible and assessed an RFC for sedentary work with limitations.
ALJ relied on uncontradicted opinions from two state agency medical consultants, two state psychological consultants, and a consultative psychiatrist (Dr. Whitten).
Medical records showed cardiac stability post-surgery, normal cardiac exams, therapeutic INR levels, and cardiologist notes that Klein could perform daily activities.
ALJ excluded Klein’s claimed need to lie down as not credible and found the cardiac impairment stable based on records months after surgery.
Vocational expert testimony, based on the ALJ’s RFC and credibility findings, supported a finding of non-disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ gave legally sufficient reasons to discount Klein’s subjective symptom testimony	Klein argued her complaints were credible and tied to objective impairment	ALJ argued testimony conflicted with medical evidence, daily activities, and medical opinions	Affirmed: ALJ provided clear and convincing reasons (medical inconsistency, activities, opinion evidence)
Whether RFC (sedentary work with limitations) was supported by substantial evidence	Klein argued RFC failed to account for need to lie down and cardiac limits	ALJ relied on multiple medical and psychological opinions and stable cardiac findings	Affirmed: RFC supported by uncontradicted expert opinions and record evidence
Whether ALJ failed to fully and fairly develop the record regarding cardiac impairment	Klein contended ALJ ignored or insufficiently developed cardiac testing and timing post-surgery	ALJ relied on later records showing stability and included the cited records in the decision	Affirmed: ALJ appropriately developed record; substantial evidence supports stability finding
Whether vocational expert testimony supported non-disability finding	Klein argued hypothetical omitted credible limitations and potential DOT inconsistencies	ALJ explained why omitted subjective limitations were disbelieved and found basis to rely on VE	Affirmed: VE testimony constituted substantial evidence and ALJ justified reliance

Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (ALJ must give clear and convincing reasons to reject claimant’s symptom testimony when impairment shown and no malingering)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (standards for evaluating subjective symptom testimony)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (daily activities may undermine claimed severity)
Stubbs-Danielson v. Astrue, 539 F.3d 1169 (9th Cir. 2008) (ALJ may rely on medical opinion inconsistencies)
Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (medical inconsistency as reason to discount subjective complaints)
Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (RFC must be supported by substantial evidence)
Batson v. Comm’r Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (ALJ need not include non-credible testimony in RFC)
Higbee v. Sullivan, 975 F.2d 558 (9th Cir. 1992) (duty to develop record for unrepresented claimants)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (substantial evidence review of medical-record-based findings)
Light v. Soc. Sec. Admin., 119 F.3d 789 (9th Cir. 1997) (ALJ must explain rationale for discounting subjective complaints omitted from VE hypothetical)
Massachi v. Astrue, 486 F.3d 1149 (9th Cir. 2007) (basis for relying on vocational expert despite DOT inconsistencies)