Fowler v. Commissioner of Social Security, 3:22-cv-05661

Plaintiff (59) applied for SSI and earlier for DIB; originally alleged onset 2004, later amended to December 21, 2016; DIB withdrawn because insured status expired in 2006. Appeals Council remanded; ALJ issued a denial on April 5, 2022.
No past relevant work; primary dispute centered on mental-health-related limitations (schizophrenia, blackouts, panic attacks).
Medical record includes multiple inpatient psychiatric admissions but frequent notations of symptom reduction and stabilization with medication and treatment.
Outpatient notes reflect engagement in counseling, part‑time work (Goodwill), community college classes, improved housing and social activity, and ability to run errands by bus.
ALJ discounted Plaintiff’s symptom testimony primarily because symptoms improved with medication/treatment and because Plaintiff’s daily activities contradicted her claimed limitations; ALJ also cited Plaintiff’s reluctance to apply for jobs for non‑medical reasons (criminal record).
District Court affirmed the ALJ, holding the credibility finding was supported by substantial evidence and any defective reason was harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ erred in discounting Plaintiff’s mental‑health symptom testimony	ALJ improperly rejected testimony; record shows ongoing anxiety/depression and Plaintiff couldn’t sustain work before Dec 2020; Commissioner selectively cited records	ALJ reasonably discounted testimony because symptoms generally improved with medication/treatment, Plaintiff’s daily activities were inconsistent with disabling limitations, and Plaintiff gave non‑medical reasons for not applying to work	Affirmed. ALJ’s reasons (improvement with treatment; inconsistent daily activities) are specific, clear and convincing and supported by substantial evidence; any erroneous reason was harmless

Ford v. Saul, 950 F.3d 1141 (9th Cir. 2020) (standards for ALJ review and sequential evaluation)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (clear and convincing reasons required to discredit symptom testimony absent malingering)
Warre ex rel. E.T. IV v. Comm’r SSA, 439 F.3d 1001 (9th Cir. 2006) (impairments controllable with medication are not disabling)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (when evidence admits more than one rational interpretation, court must uphold ALJ’s reasonable interpretation)
Carmickle v. Comm’r SSA, 533 F.3d 1155 (9th Cir. 2008) (harmless error doctrine in credibility findings)
Orn v. Astrue, 495 F.3d 625 (9th Cir. 2007) (daily activities may support discounting subjective symptom testimony)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (non‑medical reasons for not working can undermine disability claim)
Ghanim v. Colvin, 763 F.3d 1154 (9th Cir. 2014) (court must consider the entire record and not isolate supporting evidence)