Leslie Woods v. Kilolo Kijakazi
32 F.4th 785
| 9th Cir. | 2022Background
- Leslie Woods applied for disability insurance benefits and SSI in July 2017; ALJ denied benefits, Appeals Council denied review, and the district court affirmed.
- ALJ found two severe impairments (cervical degenerative disc disease; osteoarthritis of hip and knees) and deemed other claimed impairments nonsevere.
- Psychologist Dr. Karla Rae Causeya examined Woods and opined marked/extreme cognitive limitations (memory, concentration, pace, adaptation); ALJ rejected that opinion.
- ALJ assessed an RFC for light work with some postural limits and concluded Woods could perform past work as a cosmetologist/hairstylist.
- The Ninth Circuit addressed whether the SSA’s 2017 medical-evidence regulations displaced the court’s longtime “specific and legitimate” rule for rejecting treating/examining opinions.
- Court held the 2017 regs eliminate the treating/examining hierarchy and the heightened “specific and legitimate” requirement, but relationship factors remain relevant; ALJ’s reasoning was supported by substantial evidence, so the denial was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 2017 SSA medical-evidence regulations displaced Ninth Circuit treating/examining hierarchy and the "specific and legitimate" standard | Woods: prior caselaw (e.g., Murray/Lester) still requires specific-and-legitimate reasons to reject treating/examining opinions | Government: 2017 regulations eliminate deference and the hierarchical weight scheme; ALJ need only show substantial-evidence support and explain persuasiveness under new factors | The regs displaced the prior hierarchy and specific-and-legitimate rule; ALJs need not give controlling weight but must articulate persuasiveness based on supportability and consistency; relationship factors remain relevant but not presumptively dispositive. |
| Whether ALJ properly rejected Dr. Causeya’s cognitive limitations opinion | Woods: ALJ failed to give required specific reasons and ignored supporting mental-health treatment evidence | Kijakazi: ALJ permissibly found Causeya’s opinion inconsistent with other treating notes, mental-status exams, and claimant’s activities | ALJ permissibly found Causeya’s opinion inconsistent with other record evidence (e.g., normal cognitive findings, treatment notes that did not document severe cognitive deficits); substantial evidence supports rejection. |
| Whether ALJ’s RFC omitted legitimately supported physical/mental limitations | Woods: ALJ failed to account for prolonged standing limits and mental limitations from psycho-diagnostic evaluation and treatment | Kijakazi: ALJ considered symptom testimony, NP/PRN opinions, imaging, conservative treatment, and paragraph B mental findings; some opinions found unpersuasive as unsupported or inconsistent | ALJ adequately considered physical and mental evidence; found some limitations mild and incorporated them into RFC; substantial evidence supports RFC and the conclusion that Woods can perform past work. |
Key Cases Cited
- Lester v. Chater, 81 F.3d 821 (9th Cir.) (treating/examining weight framework)
- Murray v. Heckler, 722 F.2d 499 (9th Cir.) (specific-and-legitimate reasons requirement)
- Biestek v. Berryhill, 139 S. Ct. 1148 (Supreme Court) (definition and scope of substantial-evidence review)
- Bowen v. Yuckert, 482 U.S. 137 (Supreme Court) (agency authority to promulgate evidentiary rules)
- Smith v. Kijakazi, 14 F.4th 1108 (9th Cir.) (discussion of medical-opinion tiers)
- Ford v. Saul, 950 F.3d 1141 (9th Cir.) (weight given to treating/examining opinions)
- Benton ex rel. Benton v. Barnhart, 331 F.3d 1030 (9th Cir.) (nonexamining-physician evidence limits)
- Black & Decker Disability Plan v. Nord, 538 U.S. 822 (Supreme Court) (concerns about bias from rules favoring treating-source evidence)