Hollenhors v. Commissioner Social Security Administration
3:23-cv-01375
| D. Or. | Nov 18, 2024Background
- Plaintiff Beno H., born May 1990, appealed the denial of his Supplemental Security Income (SSI) claim based on multiple physical and mental conditions, chiefly chronic migraines and side effects from medication.
- The Administrative Law Judge (ALJ) denied Plaintiff's application after a hearing, finding that Plaintiff was not disabled and could perform certain jobs in the national economy.
- The ALJ determined Plaintiff had several severe impairments (migraines, hypertension, sleep apnea, etc.), but that none met or equaled a listed impairment.
- The ALJ formulated a residual functional capacity (RFC) for medium work with specific limitations, including restrictions on climbing, exposure to extreme environments, and workplace hazards.
- Plaintiff argued on appeal that the RFC did not appropriately account for all his migraine symptoms, triggers, and dizziness from medication side effects.
- The Court reviewed whether the ALJ's RFC determination and denial of benefits were free of legal error and supported by substantial evidence in the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the RFC failed to account for the frequency/severity of Plaintiff's migraines | ALJ ignored evidence of frequent, severe migraines that required Plaintiff to rest, rendering him disabled | ALJ properly discounted symptom testimony because it was not corroborated by medical evidence | ALJ did not err; substantial evidence supported discounting symptom testimony |
| Whether the RFC should include additional limitations for migraine triggers (light, sound, smells, Clorox) | RFC did not fully account for Plaintiff's sensitivity to stated triggers, making listed jobs inappropriate | ALJ included only limitations supported by substantial evidence, not subjective reports unsupported by objective evidence | ALJ did not err; RFC need not include unsupported limitations |
| Whether the ALJ erred by relying on Plaintiff's work history to discount symptom testimony | Plaintiff argued past work may not have been performed without accommodations for migraines | Defendant argued work history is relevant regardless of alleged accommodations | ALJ properly considered work history in evaluating credibility |
| Whether the RFC failed to account for dizziness from medication side effects | RFC's hazard restrictions were insufficient in view of Plaintiff's dizziness; evidence supported greater limitations | Medical evidence did not show disabling dizziness; symptom testimony was largely uncorroborated and inconsistently reported | ALJ did not err; RFC's hazard restrictions were sufficient and supported |
Key Cases Cited
- Bray v. Comm’r of Soc. Sec. Admin., 554 F.3d 1219 (9th Cir. 2009) (substantial evidence standard for review of Commissioner’s findings)
- Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (ALJ need only include supported limitations in RFC)
- Greger v. Barnhart, 464 F.3d 968 (9th Cir. 2006) (ALJ may discount symptom testimony not supported by medical evidence)
- Tackett v. Apfel, 180 F.3d 1094 (9th Cir. 1999) (framework for step five burden in sequential evaluation and limitations in hypothetical to VE)