Hughes v. Commissioner Social Security Administration, 6:15-cv-02271

Plaintiff Helen Hughes filed for Disability Insurance Benefits on behalf of Ray Hughes (application filed Sept. 6, 2012), alleging onset in 2004; date last insured was Dec. 31, 2010.
ALJ first denied benefits; Appeals Council denial; District Court reversed and remanded in 2014; ALJ held a new hearing and again found Hughes not disabled (decision dated Aug. 28, 2015).
ALJ found severe impairments: knee osteoarthritis (post-arthroscopy, prior malleolus fractures) and obesity; no listing-level impairment found.
Residual functional capacity (RFC) through the date last insured: light work with specific standing/walking/sitting and postural limitations (e.g., occasional ladders, occasional crouch/kneel/crawl).
At step four ALJ found Hughes could not perform past relevant work; at step five ALJ found transferable skills and jobs in significant numbers (e.g., parts salesperson, invoice control clerk), concluding not disabled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hughes met Listing 1.02A (major dysfunction of a joint) at step three	Hughes contends knee impairments met or equaled Listing 1.02A	Commissioner argues record lacks objective imaging and evidence of inability to ambulate effectively; conservative treatment and normal gait/ROM undermines listing	Court held Hughes did not meet Listing 1.02A; ALJ reasonably found no inability to ambulate and no imaging evidence supporting listing
Whether ALJ properly weighed Dr. Anthony Francis’s opinion regarding listing equivalence	Plaintiff argues Dr. Francis’s opinion supports meeting Listing 1.02A	Commissioner and ALJ relied on Dr. Francis’s equivocal statements and other record evidence to reject listing-level finding	Court found Dr. Francis’s own equivocation and reliance on anecdotal evidence insufficient; ALJ properly resolved conflicts and declined to find listing met

Lewis v. Astrue, 498 F.3d 909 (9th Cir. 2007) (standard for reviewing Commissioner findings)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (weighing evidence supporting and detracting from ALJ conclusion)
Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (court must consider both supporting and detracting evidence)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (Commissioner decision upheld when supported by rational inferences)
Tackett v. Apfel, 180 F.3d 1094 (9th Cir. 1999) (burden and standards regarding symptom testimony and medical evidence at step three)
Carmickle v. Comm’r, 533 F.3d 1155 (9th Cir. 2008) (ALJ resolves conflicts among physicians’ opinions)
Edlund v. Massanari, 253 F.3d 1152 (9th Cir. 2001) (reviewing court must not substitute its judgment for Commissioner)
Ryan v. Comm’r of Soc. Sec. Admin., 528 F.3d 1194 (9th Cir. 2008) (deference to ALJ credibility and factual findings)