Leticia Ramirez v. Andrew Saul, 5:20-cv-01044

Plaintiff Leticia R. applied for Title II disability benefits alleging onset of September 1, 2014; ALJ held a hearing March 27, 2019, and issued an unfavorable decision April 10, 2019.
ALJ found severe impairments: obesity and degenerative joint disease of the cervical spine and left upper extremity; RFC limited to light work with postural and left-arm limits.
Based on that RFC and VE testimony, ALJ concluded Plaintiff could perform her past work as an electronics inspector and was not disabled.
Medical record before the ALJ showed episodic, mostly conservative treatment (primary care and pain specialists), a November 2016 consultative exam with largely normal exam findings and only left-arm frequent-use restriction, and gaps in treatment/prescription pain meds during 2014–2017.
At hearing Plaintiff testified to constant pain, frequent need to lie down, medication side effects (vomiting), very limited standing, and reliance on lidocaine patches; records reflected travel, daily driving, and inconsistent symptom reporting.
Magistrate Judge Scott affirmed: ALJ gave specific, clear and convincing reasons to discount subjective symptom testimony—objective findings inconsistent with claimed limitations, treatment gaps / conservative care, and inconsistent reporting of medication side effects—and those reasons were supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly discounted Plaintiff’s subjective symptom testimony	ALJ impermissibly relied on lack of objective corroboration and isolated gaps, failing to view record as a whole	ALJ provided specific, clear and convincing reasons: inconsistency with objective findings, gaps/ conservative treatment, and inconsistent reports about med side effects	Affirmed — ALJ’s reasons were clear and convincing and supported by substantial evidence

Trevizo v. Berryhill, 871 F.3d 664 (9th Cir. 2017) (two-step framework for evaluating claimant symptom testimony)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (ALJ must find objective impairments that could produce alleged symptoms and give clear, convincing reasons to reject testimony)
Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (courts defer to ALJ if supported by substantial evidence)
Marsh v. Colvin, 792 F.3d 1170 (9th Cir. 2015) (treatment that is routine/conservative, gaps, and absence of expected medication support adverse credibility findings)
Osenbrock v. Apfel, 240 F.3d 1157 (9th Cir. 2001) (ALJ may consider lack of significant pain regimen in credibility evaluation)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (ALJ may consider inconsistencies between testimony and medical evidence or claimant’s conduct)
Robbins v. Social Security Admin., 466 F.3d 880 (9th Cir. 2006) (objective evidence cannot be sole basis to reject subjective testimony, but may be considered)