Evans Madison v. Nancy Berryhill
676 F. App'x 633
| 9th Cir. | 2017Background
- Evans L. Madison applied for Supplemental Security Income; ALJ denied benefits at step five, finding Madison could perform jobs existing in significant numbers nationally. District court affirmed; Madison appealed.
- Madison reported disabling seizures, Raynaud’s syndrome, pain, leg weakness, and related functional limits.
- Medical records showed seizure disorder and Raynaud’s were controlled with medication and that leg weakness and seizure frequency improved after medication adjustments.
- Treating physician Timothy Joos opined Madison had gross and fine motor restrictions; examining psychologist David Widlan assigned a low GAF and reported limiting psychiatric symptoms.
- Madison sought narcotic pain medication from multiple doctors; several declined to prescribe, which the ALJ considered inconsistent with claimed pain levels.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were Madison’s symptom reports (credibility) properly evaluated? | ALJ failed to credit Madison’s testimony of disabling seizures/pain. | ALJ identified medical evidence of controlled seizures, inconsistent pain-treatment seeking, and records contradicting symptom severity. | ALJ gave a detailed, permissible credibility assessment and discounted symptom testimony. |
| Was treating physician Joos’s opinion given proper weight? | Joos’s opinion reflects treating-doctor view of motor limitations. | ALJ discounted it because it relied on Madison’s reports and lacked supporting explanation/evidence. | ALJ provided specific and legitimate reasons to give Joos’s opinion little weight. |
| Was examining psychologist Widlan’s opinion properly discounted? | Widlan’s findings show psychiatric limits that would preclude work. | Widlan’s opinion failed to translate symptoms into concrete functional deficits and conflicted with daily activities and Madison’s limited credibility. | ALJ permissibly discounted Widlan’s opinion and the low GAF score. |
| Did ALJ err by not addressing Dr. LeBlanc’s opinion? | ALJ erred by failing to discuss LeBlanc. | Any error was harmless because later records show improvement and stabilization that undercut disability. | Error in omitting discussion of LeBlanc was harmless to the nondisability determination. |
Key Cases Cited
- Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (standards for evaluating medical opinions and symptom testimony)
- Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090 (9th Cir. 2014) (credibility assessment requirements)
- Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (inconsistencies with objective evidence can undermine claimed symptoms)
- Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (evidence of drug-seeking behavior and treatment inconsistencies affect credibility)
- Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (ALJ may discount treating opinions lacking explanation)
- Ghanim v. Colvin, 763 F.3d 1154 (9th Cir. 2014) (standards for rejecting treating physician opinions)
- Tonapetyan v. Halter, 242 F.3d 1144 (9th Cir. 2001) (ALJ may disregard an examiner’s opinion that rests on claimant’s discredited statements)
- Morgan v. Comm’r of Soc. Sec. Admin., 169 F.3d 595 (9th Cir. 1999) (medical opinions must connect symptoms to specific functional limitations)