Gonzalez v. Social Security Administration Commissioner
2:12-cv-02272
D. Ariz.Mar 19, 2014Background
- Gonzalez appeals a denial of Title XVI SSI benefits by the SSA Commissioner after an ALJ decision.
- ALJ found Gonzalez had a severe mental impairment combination but concluded she could perform light, unskilled work with no public interaction.
- AC denied review, leaving the ALJ’s decision as the final agency decision.
- Plaintiff challenged the ALJ’s handling of treating physicians’ opinions, Geary’s evidence on listings, her credibility, and lay witness evidence.
- The court analyzes the record under the substantial evidence standard and evaluates whether the ALJ’s findings are supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Treating physicians’ opinions weight | Gonzalez argues the ALJ wrongfully rejected treating doctors without clear reasons. | SSA contends the ALJ provided specific, legitimate reasons supported by the record. | ALJ provided specific, legitimate reasons supported by substantial evidence. |
| Dr. Geary’s listing findings | Geary’s post-decision opinion on Listings 12.04, 12.06, 12.07 should be considered | AC reasoning and record support upheld the ALJ’s evaluation; Geary’s opinion not controlling | Substantial evidence supports the ALJ; no legal error by ignoring Geary’s listing conclusions. |
| Credibility of subjective symptoms | ALJ failed to provide clear and convincing reasons for not fully crediting her symptom testimony | ALJ permissible to rely on objective evidence and conduct two-step credibility analysis | ALJ’s credibility findings were specific, supported by the record, and not reversible error. |
| Lay witness testimony | ALJ failed to discuss lay witness evidence as required | ALJ considered lay input within the record when forming the decision | Error for non-discussion, but harmless given substantial evidence supporting the decision. |
Key Cases Cited
- Magallanes v. Bowen, 881 F.2d 747 (9th Cir. 1989) (treating- and examining- physician conflict and framework for reasons to discredit)
- Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (substantial evidence standard; burden shifts at step five)
- Gallant v. Heckler, 753 F.2d 1450 (9th Cir. 1984) (standard for reviewing ALJ inferences when record supports multiple interpretations)
- Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (credibility evaluation requires specific findings if no malingering)
- Warre v. Comm’r of Soc. Sec. Admin., 439 F.3d 1001 (9th Cir. 2006) (impairments controlled by medication not disabling)