George Castillo v. Nancy Berryhill
693 F. App'x 659
| 9th Cir. | 2017Background
- George Castillo applied for Social Security Disability Insurance benefits in June 2011; ALJ denied; district court affirmed; Castillo appealed to the Ninth Circuit.
- Central medical evidence included a July 2012 supplemental questionnaire from treating psychiatrist Dr. R. Duane Hopson assessing marked mental limitations.
- Prior treatment notes from Dr. Hopson (Feb., Sept., Dec. 2011) showed largely normal thought processes, intact memory, and improved mood and activity (e.g., church participation).
- Castillo’s own statements indicated functional abilities (e.g., two hours attention, following written instructions, completing tasks) inconsistent with marked limitations.
- Exam notes from Dr. James A. Pruitt (July 2012) indicated Castillo could follow three- and four-step commands, undermining the extreme limitations found in Hopson’s July 2012 assessment.
- The ALJ concluded Castillo’s mental impairments were nonsevere and declined to give controlling weight to Hopson’s July 2012 opinion; the Ninth Circuit affirmed, finding substantial evidence supported the ALJ’s reasons.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in rejecting treating psychiatrist Hopson’s July 2012 assessment | Hopson’s treating-source opinion showed marked mental limitations and should be given controlling weight | ALJ argued Hopson’s July 2012 opinion conflicted with his prior notes, other exam findings, and claimant statements, so it need not be controlling | ALJ did not err; specific, legitimate reasons and substantial evidence supported discounting Hopson’s July 2012 assessment |
| Whether Castillo’s mental impairments are severe | Castillo contends his mental impairments cause functional limitations precluding work | Commissioner contends record activities and objective findings show no more than minimal limitation | Court held impairments are nonsevere; substantial evidence (daily activities, independent living, exam findings) supports ALJ’s conclusion |
Key Cases Cited
- Ghanim v. Colvin, 763 F.3d 1154 (9th Cir. 2014) (standard for reviewing ALJ disability determinations and treating-source opinion weight)
- Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (substantial-evidence and legal-standard review for ALJ decisions)
- Burrell v. Colvin, 775 F.3d 1133 (9th Cir. 2014) (treating physician opinions must be supported by the record to be controlling)