Lynetta Marie Ward v. Carolyn W. Colvin, 3:16-cv-05323

Background

Plaintiff Lynetta Ward applied for Supplemental Security Income (Title XVI) alleging disability from mental impairments (PTSD, depression, anxiety, and schizoaffective symptoms) with an onset date of December 31, 2011; SSA denied benefits and the ALJ affirmed; Appeals Council denied review; Ward sued.
Medical record includes consultative exams (Dr. Gaasbeek: major depressive disorder with psychotic features; Dr. Phillips: hypertension, severe affective disorder), an extensive neuropsychological evaluation (Dr. Franklin: schizoaffective disorder, PTSD, severe executive-function deficits), treating clinic notes (Lifelong Medical: persistent hallucinations, depression, PTSD), and earlier stabilization records documenting psychosis.
Non‑examining state agency reviewers (Drs. Luck, Morgan, Barrons) found affective disorder severe but generally concluded limitations were moderate and did not support disability; they downplayed visual hallucinations.
At hearing, Ward testified to ongoing auditory and visual hallucinations, severe depression, limited daily functioning, and intermittent substance use; the VE testified that being unable to complete a normal workday or having marked reductions in attention would be work‑preclusive.
The ALJ gave significant weight to Dr. Gaasbeek and the state agency reviewers, discounted Dr. Franklin and treating/Lifelong records, found severe impairments limited to major depressive disorder and polysubstance dependence (nonsevere: hypertension, ganglion cysts), assessed an RFC for medium, unskilled, low‑stress work, and concluded Ward could perform past relevant work as a fast‑food cashier.
The District Court granted Ward’s summary judgment motion, concluding the ALJ erred in weighing medical opinions, step‑two severity findings, step‑three listing analysis, RFC formulation, and credibility assessment; the case was vacated and remanded for further proceedings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ’s weighing of medical opinions	ALJ improperly discredited examining psychologist Dr. Franklin and treating Lifelong records and over-relied on non‑examining reviewers	ALJ permissibly weighed evidence and gave proper weight to consultative and state agency opinions	Court: ALJ erred; failed to provide specific, legitimate reasons to discount Dr. Franklin and treating records and improperly relied on non‑examining opinions inconsistent with record
Step Two severity findings	ALJ failed to find schizoaffective disorder, PTSD, and anxiety severe despite objective testing and treating notes	Any omission harmless because ALJ considered mental impairments in RFC	Court: Error — ALJ should have inquired into and considered severity of those diagnoses at step two
Step Three (Listings)	ALJ neglected listings 12.03 (psychotic) and 12.06 (anxiety) despite evidence of hallucinations, PTSD symptoms, and severe anxiety	ALJ considered mental impairments under appropriate listings (12.04, 12.09) and RFC evaluation covers deficits	Court: Error — failure to consider 12.03 and 12.06 was improper given record evidence
Credibility / RFC and VE hypotheticals	Ward’s testimony is supported by objective testing (Dr. Franklin) and VE said core limitations would be work‑preclusive; ALJ’s credibility reasons not clear and convincing	ALJ reasonably found inconsistencies and limited treatment; RFC and VE testimony support nondisability	Court: ALJ’s credibility reasons were not clear and convincing; RFC unsupported because it ignored or discounted relevant medical opinions and conditions

Key Cases Cited

Molina v. Astrue, 674 F.3d 1104 (9th Cir.) (defines "substantial evidence" standard in disability review)
Orn v. Astrue, 495 F.3d 625 (9th Cir.) (opinions of examining physicians generally entitled to greater weight)
Garrison v. Colvin, 759 F.3d 995 (9th Cir.) (ALJ must give specific, legitimate reasons when rejecting treating/examining opinions; describes credit‑as‑true framework)
Lester v. Chater, 81 F.3d 821 (9th Cir.) (examining physician’s opinion cannot be rejected without specific and legitimate reasons)
Morgan v. Comm’r, 169 F.3d 595 (9th Cir.) (treating physician rule and limits on non‑examining physicians’ opinions)
Hill v. Astrue, 698 F.3d 1153 (9th Cir.) (vocational expert hypotheticals must include all limitations reflected in the RFC)
Benecke v. Barnhart, 379 F.3d 587 (9th Cir.) (remand for further proceedings is standard when ALJ error found)
Treichler v. Comm’r, 775 F.3d 1090 (9th Cir.) (district court should not automatically credit discredited evidence if record is ambiguous)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir.) (two‑step test for evaluating claimant testimony about symptoms)
Brown‑Hunter v. Colvin, 806 F.3d 487 (9th Cir.) (ALJ must specify which testimony is rejected and provide reasons)