Molina v. Astrue, 674 F.3d 1104

Molina filed applications for disability benefits and supplemental security income on Sept. 22, 2006 alleging panic and anxiety impairments since Sept. 7, 2002.
Molina's primary care provider, physician's assistant Molly Wheelwright, diagnosed longstanding panic disorder and noted emergency visits for panic attacks; Lorazepam used to control symptoms.
Wheelwright later completed a Mental Impairment Questionnaire with severe functional limitations, but provided little supporting explanation and inconsistent prognosis.
Dr. Hunter Yost, a psychiatrist, examined Molina in Nov. 2006 and found no disabling impairment; concluded the disorder was controlled with Lorazepam and did not impose work limitations; state DDS reviewed similarly.
ALJ denied benefits, weighing Dr. Yost's opinion more heavily and discounting Wheelwright as a non-physician 'other source' with conclusory and inconsistent statements; family-submitted lay statements were not discussed in detail.
On appeal, Molina contends the ALJ erred by (1) giving inadequate weight to Wheelwright, (2) improperly evaluating credibility, and (3) rejecting lay testimony without comment; the district court affirmed the denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to Wheelwright's opinions	Molina argues Wheelwright's treating-source opinions should be given greater weight.	Astrue contends Wheelwright is an 'other source' not entitled to full medical-source deference and that the ALJ properly discounted her conclusions.	ALJ properly discounted Wheelwright as an 'other source' and credited Dr. Yost; reasons supported by substantial evidence.
Molina's credibility assessment	Molina asserts the ALJ erred in discrediting her subjective complaints.	ALJ applied standard credibility framework with specific, clear, and convincing reasons; daily activities and demeanor corroborate rejection.	ALJ's credibility finding upheld; supported by substantial evidence and consistency with medical evidence.
Consideration of lay witness testimony	ALJ erred by not commenting on lay witness testimony from Molina's family.	Regulations require consideration but do not mandate individualized explanation for each lay witness.	ALJ's failure to comment was harmless given reasons rejecting Molina's own testimony similarly apply to lay witnesses.

Valentine v. Comm'r Soc. Sec. Admin., 574 F.3d 685 (9th Cir. 2009) (substantial evidence standard for credibility; check-off reports discussed)
Stout v. Commissioner, SSA, 454 F.3d 1050 (9th Cir. 2006) (harmless-error framework for lay-witness testimony when properly rejected)
Robbins v. Soc. Sec. Admin., 466 F.3d 880 (9th Cir. 2006) (lay witness testimony can be harmless if properly contextualized)
Stout v. Commissioner, SSA, 454 F.3d 1050 (9th Cir. 2006) (harmless error analysis for ignored lay testimony)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (standard for evaluating credibility; substantial evidence rule)
Parra v. Astrue, 481 F.3d 742 (9th Cir. 2007) (five-step disability evaluation framework; burden on claimant)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (weight given to medical opinions; reliance on specialty)
Shinseki v. Sanders, 556 U.S. 396 (2009) (harmless-error review applied to civil cases; no rigid presumptions)
Gomez v. Chater, 74 F.3d 967 (9th Cir. 1996) (nurse practitioners may be treated as acceptable medical sources when supervised)
Sanders (Shinseki v. Sanders) citation, 556 U.S. 396 (2009) (harmless-error standard; case-specific evaluation)