Melissa Petrini v. Nancy Berryhill
705 F. App'x 511
| 9th Cir. | 2017Background
- Melissa Petrini appealed the denial of her application for Supplemental Security Income (SSI) based on alleged mental impairments.
- The ALJ evaluated medical opinion evidence from treating/consulting physicians including Drs. Rutter, Kalman, Palmer, and Bilik and issued an RFC limiting Petrini accordingly.
- The ALJ assigned limited weight to Dr. Rutter’s and Dr. Kalman’s opinions, finding internal inconsistencies and reliance on Petrini’s subjective reports, which the ALJ found not credible.
- The ALJ gave greater effect to Drs. Bilik’s and Palmer’s opinions and incorporated their limitations into the RFC, though not verbatim.
- The Ninth Circuit reviewed whether the ALJ properly weighed medical opinions and translated them into an RFC and whether the ALJ erred in hypotheticals to the vocational expert.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in weighing treating/consulting opinions | ALJ improperly discounted Rutter and Kalman; those opinions should factor into RFC | ALJ permissibly gave limited weight due to internal inconsistencies and reliance on Petrini’s noncredible reports | Affirmed: ALJ gave specific, legitimate, supported reasons for limited weight |
| Whether ALJ erred in translating medical opinions into RFC | RFC failed to capture limitations in doctor opinions | RFC appropriately incorporated limits from Bilik and Palmer even if phrasing differed | Affirmed: ALJ may translate clinical findings into a succinct RFC |
| Whether ALJ had to include Rutter/Kalman limitations in hypotheticals | ALJ’s hypotheticals omitted these doctors’ limits, which prejudiced outcome | Because opinions were properly discounted, ALJ need not include them in hypotheticals | Affirmed: No error in limiting hypotheticals to RFC-supported conditions |
| Whether remand for benefits required | Remand for benefits may be appropriate given record | Court need not reach benefit-remand question after affirmance | Not reached; decision affirmed |
Key Cases Cited
- Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (ALJ may reject physician opinion for specific, legitimate reasons supported by substantial evidence)
- Morgan v. Comm’r of Soc. Sec. Admin., 169 F.3d 595 (9th Cir. 1999) (physician opinions premised on claimant’s discredited symptom testimony may be discounted)
- Stubbs-Danielson v. Astrue, 539 F.3d 1169 (9th Cir. 2008) (ALJ responsible for translating clinical findings into RFC)
- Rounds v. Comm’r Soc. Sec. Admin., 807 F.3d 996 (9th Cir. 2015) (affirming ALJ’s role in incorporating medical opinions into RFC)
- Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (ALJ need not adopt opinions that were permissibly discounted)