Maria Guadalupe Inda De Arias v. Commissioner of Social Security Administration, 2:16-cv-06226

Plaintiff Maria Guadalupe Inda De Arias applied for Social Security disability benefits (Title II) alleging disability beginning May 1, 2012; application was denied and an ALJ held a hearing on December 22, 2014.
The ALJ found severe impairments (arthritis, degenerative disc disease, fibromyalgia, obesity, history of hyperthyroidism, bilateral plantar fasciitis) but concluded Plaintiff retained a sedentary RFC with certain postural limits.
The ALJ determined Plaintiff could perform past relevant work as a customer service representative and therefore was not disabled (decision dated February 19, 2015); the Appeals Council denied review.
The sole contested issue on judicial review was whether the ALJ erred in discounting Plaintiff’s subjective symptom testimony (credibility).
The ALJ gave three reasons for discounting credibility: (1) failure to follow prescribed treatments consistently; (2) daily activities inconsistent with claimed limitations; and (3) lack of objective medical evidence supporting the severity of symptoms.
The district court applied the Ninth Circuit’s substantial-evidence/clear-and-convincing standards and affirmed the Commissioner’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ erred in discounting Plaintiff’s subjective symptom testimony	Inda De Arias argued the ALJ improperly rejected her testimony and that treatment noncompliance was due to financial limits	Commissioner argued the ALJ gave valid clear-and-convincing reasons (failure to follow treatment, inconsistent daily activities, weak objective support)	Court held ALJ gave specific, clear-and-convincing reasons supported by substantial evidence and did not err

Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090 (9th Cir. 2014) (substantial-evidence review standards)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (reviewing the record as a whole standard)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (clear-and-convincing reasons required when no evidence of malingering)
Cotton v. Bowen, 799 F.2d 1403 (9th Cir. 1986) (treatment noncompliance as basis to discount testimony)
Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (upholding rational ALJ interpretations of ambiguous evidence)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (daily activities may undermine subjective symptom claims)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (failure to follow prescribed treatment may bear on credibility)
Morgan v. Comm’r of Soc. Sec. Admin., 169 F.3d 595 (9th Cir. 1999) (ALJ may consider objective medical evidence when evaluating subjective complaints)
Bray v. Comm’r of Soc. Sec. Admin., 554 F.3d 1219 (9th Cir. 2009) (inconsistency between alleged limitations and activities supports adverse credibility finding)