Prince v. Astrue, 3:12-cv-05609

Ronald V. Prince applied for disability benefits; ALJ denied benefits (decision June 17, 2011); Appeals Council denied review; Prince sought judicial review.
Claimant's alleged disabling conditions: bipolar disorder, PTSD, depression, HIV (asymptomatic with undetectable viral load), shoulder/back pain, diarrhea/fatigue.
Relevant medical opinions: Dr. Taylor (examining psychologist—marked mental limitations, GAF 40), Dr. El‑Sokkary (examining psychologist—able to do simple tasks, GAF 60), Dr. Foster‑Valdez (state non‑examining consultant—moderate social/interaction limits), various treating providers (APEB notes; Dr. Bouvier letter asserting total disability).
ALJ RFC: medium exertion; sit/stand/walk about 6 hours/8‑hour day; no overhead right‑arm reaching; simple/entry‑level tasks (SVP 2); occasional interaction with coworkers/public; avoid concentrated respiratory irritants. ALJ gave great weight to Dr. Foster‑Valdez and Dr. Seu, some weight to Dr. El‑Sokkary, little/no weight to several treating/other examiners.
ALJ found claimant less than fully credible based on (1) medical record showing well‑controlled HIV and only mild objective findings, (2) daily activities (self‑care, caring for grandson), and (3) inconsistent statement that inability to work was due to criminal history rather than medical impairment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ improperly rejected medical opinions (Dr. Taylor, Dr. Foster‑Valdez conflicts)	Prince: ALJ ignored/failed to give proper weight to examining/treating opinions (Dr. Taylor) and improperly failed to incorporate Dr. Foster‑Valdez’s moderate limitation re: responding to supervisors — which VE said would preclude work.	Commissioner: ALJ reasonably weighed opinions, expressly adopted parts of Dr. Foster‑Valdez and relied on Dr. El‑Sokkary to resolve conflict; Dr. Taylor’s opinion was attorney‑referred and inconsistent with his own exam notes.	Court: ALJ erred by failing to explain why she adopted only parts of Dr. Foster‑Valdez while rejecting the conflicting portion; the omission was not harmless because a moderate supervisor‑interaction limitation would eliminate work. Remand required for proper consideration of these opinions.
Whether the ALJ gave legally sufficient reasons to discount claimant’s testimony	Prince: ALJ failed to provide specific, clear, and convincing reasons to reject his symptom testimony.	Commissioner: ALJ gave clear and convincing reasons — lack of objective support, daily activities, and inconsistent statements.	Court: ALJ’s adverse credibility finding is supported by specific, clear, and convincing reasons (medical record showing well‑controlled HIV, activities, inconsistent statements); court upheld credibility determination.

Vasquez v. Astrue, 572 F.3d 586 (9th Cir.) (standard for district court review: ALJ findings set aside only for legal error or lack of substantial evidence)
Andrews v. Shalala, 53 F.3d 1035 (9th Cir.) (definition of substantial evidence)
Tackett v. Apfel, 180 F.3d 1094 (9th Cir.) (burden of proof allocation and deference to ALJ when record supports either outcome)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir.) (two‑step credibility analysis for symptom testimony)
Morgan v. Comm’r, 169 F.3d 595 (9th Cir.) (treatment of medical opinions; non‑examining physicians cannot alone outweigh examining/treating opinions)
Burch v. Barnhart, 400 F.3d 676 (9th Cir.) (lack of objective medical evidence may be considered in credibility analysis)
Fair v. Bowen, 885 F.2d 597 (9th Cir.) (daily activities may support an adverse credibility determination)
Molina v. Astrue, 674 F.3d 1104 (9th Cir.) (harmless‑error doctrine in Social Security cases)