Henrietta Renteria v. Carolyn W. Colvin, 5:16-cv-01612

Plaintiff Henrietta Renteria applied for DIB alleging disability beginning September 3, 2011; ALJ denied benefits and Appeals Council denied review.
ALJ found severe impairments (cervical degenerative disc disease, bilateral shoulder conditions, trigger thumb, carpal tunnel history) but not per se disabling.
Treating orthopedist Dr. Neil Halbridge (workers’ compensation treating physician) issued 2014 reports: permanent and stationary, recommended "modified work," and imposed restrictions including no repetitive overhead work bilaterally, no repetitive work at/above shoulder level, lifting limited to 15 lbs, and no repetitive right-hand gripping.
ALJ gave "significant weight" to Dr. Halbridge generally but did not expressly reconcile or translate his use of the workers’ compensation term "repetitive" into Social Security functional terms, and found the claimant could "frequently reach at or above shoulder level."
ALJ relied on vocational expert testimony identifying four representative jobs (lens gauger, table worker, ticket taker, swatch clerk), each requiring "frequent" reaching/handling (defined in DOT as 1/3 to 2/3 of the time).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly considered/translated the treating physician’s "repetitive" restriction (workers’ comp term) into the Social Security RFC	"Repetitive" is a workers’ comp term of art equating to ~50% of time; ALJ failed to translate this to Social Security’s "frequent" (33–67%) standard or explain how VE jobs with "frequent" reaching are consistent with a 50% limit	ALJ incorporated Dr. Halbridge’s opinions into the RFC; consultative and state agency opinions supporting at least medium work also support ALJ’s RFC	Court held ALJ erred by ignoring the term-of-art meaning of "repetitive" and failing to reconcile it with the RFC; error was not harmless and remand is required for further proceedings

Orn v. Astrue, 495 F.3d 625 (9th Cir. 2007) (standard of review: substantial evidence governs ALJ factual findings)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (ALJ findings must be upheld if supported by reasonable inferences)
Brown-Hunter v. Colvin, 806 F.3d 487 (9th Cir. 2015) (harmless error standard and review limited to reasons ALJ actually relied on)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (ALJ must provide a substantive basis when rejecting or assigning little weight to a treating opinion)
Trevizo v. Berryhill, 862 F.3d 987 (9th Cir. 2017) (weighting treating opinions; clear-and-convincing or specific-and-legitimate reasons required)
Magallanes v. Bowen, 881 F.2d 747 (9th Cir. 1989) (ALJ may reject a doctor’s opinion by detailed summary of conflicting evidence and interpretation)
Booth v. Barnhart, 181 F. Supp. 2d 1099 (C.D. Cal. 2002) (ALJ may not disregard a worker’s compensation doctor’s opinion merely because of its terminology; must translate or explain differences)