Price v. Colvin, 2:13-cv-01735

Plaintiff Darlene Price applied for Social Security disability and SSI in Feb. 2010 alleging fibromyalgia and depression with an onset date of Aug. 10, 2008.
An ALJ denied benefits after a July 14, 2011 hearing, finding Price could perform the full range of light work despite some mental limitations and thus was not disabled. The Appeals Council denied review.
Price sought judicial review in district court and moved to remand, arguing the ALJ improperly rejected the opinion of her expert, Dr. Joseph White, and erred in finding only minimal mental impairment.
The magistrate judge recommended denying remand and affirming the ALJ; the district court conducted de novo review of Price’s objection.
The ALJ’s mental-impairment findings relied on multiple bases: medication-controlled symptoms, normal mental-status exam findings, absence of hospitalization/suicidal or psychotic history, treating-source statements of intact memory and concentration, robust daily activities, lack of mental-health treatment after 2011, and evidence suggesting symptom magnification.
The district court adopted the magistrate judge’s recommendation, holding the ALJ’s mental-impairment determination was supported by substantial evidence and applied correct legal standards; remand was denied and the ALJ’s decision affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ erred by finding minimal mental impairment and rejecting Dr. White’s opinion	Price contends the ALJ improperly discounted Dr. White and relied unduly on her delayed or limited mental-health treatment (citing Nguyen on underreporting of depression)	Colvin argues the ALJ considered the whole record and gave valid reasons (medication control, normal exam, intact memory/concentration, activities, lack of treatment, symptom magnification) supporting minimal impairment	Court held ALJ did not err; substantial evidence supports the minimal mental-impairment finding and rejection of Dr. White’s opinion

Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (standard for reviewing ALJ disability determinations)
Delorme v. Sullivan, 924 F.2d 841 (9th Cir. 1991) (judicial review limited to substantial evidence and correct legal standards)
Vasquez v. Astrue, 572 F.3d 586 (9th Cir. 2009) (definition and application of substantial evidence standard)
Andrews v. Shalala, 53 F.3d 1035 (9th Cir. 1995) (substantial-evidence discussion)
Nguyen v. Chater, 100 F.3d 1462 (9th Cir. 1996) (recognizing depression is often underreported; lack of treatment not dispositive)
Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (ALJ conclusions must be upheld when evidence permits more than one rational interpretation)