Laier v. Colvin
2:14-cv-02478
| D. Ariz. | Jun 15, 2015Background
- Plaintiff Ronda Lee Laier seeks review of the Commissioner’s final decision denying DIB and SSI under 42 U.S.C. § 405(g).
- ALJ’s February 22, 2013 decision found no disability; Appeals Council denied review; final decision became operative.
- Plaintiff born Oct 1958, limited education, English-speaking; prior work as dietary manager and security supervisor.
- Amended onset date of disability is Sept 1, 2010; at hearing (Nov 2012) lived with husband, daughter, and father; husband has memory impairment.
- ALJ found severe impairments: multilevel lumbar/thoracic degenerative disc disease, hip bursitis, dysthymic disorder, generalized anxiety disorder, cannabis abuse; RFC allowed full range of work with occasional public/co-worker contact.
- Plaintiff sought district court review; court affirms the Commissioner’s decision as supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly evaluated credibility | Laier argues greater symptom severity than found. | ALJ’s credibility assessments are supported by record and conservative treatment. | No reversible error; credibility rejected with specific, convincing reasons. |
| Whether the ALJ properly weighed treating/medical source opinions | Treating doctors Roy and Feldman support greater impairment. | ALJ properly limited weight due to inconsistent progress notes and reliance on subjective reports. | ALJ’s weighing of Roy and Feldman was proper; little weight given to those opinions. |
| Whether the vocational expert analysis appropriately reflected credible RFC | Hypothetical to VE did not encompass all credible limitations. | VE’s testimony grounded in credible RFC; no need to include uncredible limitations. | VE reliance on credible RFC supported; no error in vocational analysis. |
Key Cases Cited
- Vasquez v. Astrue, 572 F.3d 586 (9th Cir. 2009) (credibility requires specific, clear reasons beyond lack of objective evidence)
- Bray v. Comm’r of Soc. Sec. Admin., 554 F.3d 1219 (9th Cir. 2009) (reasons for discounting testimony must be specific and legitimate)
- Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (scope of credibility review; substantial evidence standard)
- Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (consistency with record supports credibility determinations)
- Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (harmless error; substantial evidence remains even with error)