Munguia v. Commissioner of Social Security, 5:24-cv-06297

S.M. applied for Social Security disability insurance benefits, alleging disability since September 7, 2018, due to various physical and mental impairments including small fiber neuropathy (SFN) and migraines.
The Administrative Law Judge (ALJ) denied her claim, finding some impairments severe but others (including SFN and migraines) not severe and concluded S.M. was not disabled because she could perform other available work.
After initial and reconsideration denials, the ALJ held two hearings before issuing the unfavorable decision in June 2024; S.M. then appealed to the District Court.
On review, the District Court focused on whether the ALJ properly weighed medical opinions, specifically addressed SFN, and correctly assessed S.M.'s limitations under applicable regulations.
The Court found legal errors in the ALJ's failure to properly consider and weigh all medical opinions, failure to adequately address SFN, and insufficiently reasoned rejections of key medical evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ's evaluation of medical opinions	ALJ improperly rejected all medical opinions regarding S.M.’s physical impairments, failed to discuss some opinions, and failed to analyze supportability/consistency as required.	ALJ reasonably rejected opinions as unpersuasive or duplicative; any failures were harmless.	Court agreed with S.M.; ALJ’s errors were not harmless and required remand.
Failure to consider SFN as a severe impairment	ALJ erred by not acknowledging SFN and failing to analyze it at subsequent steps, leading to an incomplete disability evaluation.	Any error in omitting SFN was harmless as it didn’t affect ultimate disability determination.	Court found step two omission harmless but failing to address SFN at step three was harmful error.
Rejection of plaintiff's testimony	ALJ did not provide legally sufficient reasons for discounting S.M.'s symptom testimony.	ALJ’s credibility determination was proper and based on the record.	Court did not reach this issue, as remand would address testimony in context of additional evidence assessment.
Remedy (immediate award vs remand)	Sought immediate award of benefits based on the record.	Further proceedings required to address deficiencies.	Court found remand for further proceedings, not immediate award, was appropriate.

Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (standard for reviewing Commissioner’s decision: must be supported by substantial evidence and free of legal error)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (ALJ errs by rejecting medical opinions without specific reasons; courts may remand for further proceedings or benefits)
Buck v. Berryhill, 869 F.3d 1040 (9th Cir. 2017) (threshold nature of step two in sequential evaluation; failure to classify as severe at step two is harmless if step proceeds)
Barnhart v. Walton, 535 U.S. 212 (2002) (definition of disability includes duration and severity requirements in Social Security context)
Treichler v. Comm'r of Soc. Sec. Admin., 775 F.3d 1090 (9th Cir. 2014) (harmless error analysis for ALJ decisions)