McLamb v. Commissioner Social Security Administration, 2:16-cv-00563

Plaintiff Katrina McLamb (born 1978) applied for DIB and SSI on August 21, 2012, alleging disability due to scoliosis and related back/leg pain.
Administrative record includes prior work as a bartender/waitress; completed 10th grade; protective filing and denials on reconsideration; hearing before ALJ Spaulding on July 10, 2014.
Medical findings: diagnoses of scoliosis, cervical and lumbar degenerative disc disease, left-sided sciatica; imaging and tests showed no spinal cord narrowing, normal nerve conduction in left lower extremity, full motor strength at times, and bone scan without acute surgical findings.
ALJ found severe impairments but determined they did not meet or equal a listing; assessed RFC for sedentary work with a sit/stand option, frequent overhead reach/fine manipulation with right arm, no ladders/scaffolds, avoid hazards.
VE testified such a person could perform jobs existing in significant numbers (order clerk, charge account clerk, taper); ALJ found McLamb not disabled; Appeals Council denied review; district court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credibility of McLamb's subjective pain testimony	McLamb says ALJ improperly rejected her symptom testimony without clear and convincing reasons	ALJ cited lack of objective support, conservative treatment, and inconsistent activity/work history as clear and convincing reasons	Court held ALJ gave legally sufficient, supported reasons; credibility rejection affirmed
RFC—sit/stand specification under SSR 96‑9p	RFC insufficient because ALJ did not state exact frequency/duration of sit/stand and claimant may need extremely frequent changes	ALJ limited claimant to jobs with a sit/stand option, consulted VE about ability to perform work while alternating and remaining on task, complying with SSR 96‑9p	Court held ALJ reasonably complied with SSR 96‑9p; RFC not erroneous
Lay witness (mother) statement	ALJ improperly rejected third‑party function report from plaintiff's mother	ALJ relied on same reasons that discredited claimant's testimony (medical evidence, activities, conservative treatment), making any error harmless	Court held rejection harmless because the lay testimony mirrored claimant's discredited statements

Bowen v. Yuckert, 482 U.S. 137 (establishes five‑step disability evaluation framework)
Smolen v. Chater, 80 F.3d 1273 (claimant need not produce objective evidence of symptom severity)
Parra v. Astrue, 481 F.3d 742 (ALJ must provide clear and convincing reasons to reject claimant testimony)
Lingenfelter v. Astrue, 504 F.3d 1028 (definition of substantial evidence and weighing record)
Molina v. Astrue, 674 F.3d 1104 (harmless‑error rule for lay witness testimony)