(SS) Buchanan v. Commissioner of Social Security
2:24-cv-02466
| E.D. Cal. | Aug 25, 2025Background
- Plaintiff Nicole Buchanan applied for SSDI/SSI alleging disability beginning January 5, 2022; ALJ denied benefits and Appeals Council declined review. Case reviewed de novo under 42 U.S.C. § 405(g).
- ALJ found severe impairments including lumbar spine disorder, asthma, hypertension, chronic systolic congestive heart failure, diabetes, obesity, depression, anxiety, and PTSD.
- ALJ assessed an RFC for the full range of light work with multiple nonexertional limits (no ladders/ropes/scaffolds, avoid pulmonary irritants/extreme temperatures, occasional posturals, no bilateral foot controls, simple routine tasks, occasional interaction, off-task up to 3%).
- ALJ discounted portions of Plaintiff’s subjective symptom testimony based on treatment notes showing no acute distress, normal exam findings from treating providers, conservative/effective treatment, modest imaging abnormalities, and reported daily activities.
- Plaintiff challenged (1) failure to consider impairments in combination, (2) failure to account for moderate mental limitations, and (3) improper rejection of subjective testimony. Court found error only in the ALJ’s evaluation of subjective statements and testimony.
- Court remanded under sentence four of 42 U.S.C. § 405(g) for further proceedings because the ALJ mischaracterized Plaintiff’s daily activities and therefore the adverse credibility finding was not supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ considered impairments in combination | Buchanan: ALJ failed to evaluate combined effect (pain, fatigue, edema, CHF, mental disorders) | Commissioner: Plaintiff offers no coherent specific evidence that ALJ failed to consider combinations; presumption ALJ followed regs | Denied — Court: Plaintiff provided no specific evidence of failure; argument fails |
| Whether RFC accounted for moderate mental limitations | Buchanan: RFC’s limits (occasional interaction, off-task 3%) insufficient for moderate mental limitations like flashbacks and concentration issues | Commissioner: RFC addressed social limits and off-task time; no record evidence of frequent flashbacks beyond accounted-for distraction | Denied — Court: ALJ’s mental restrictions were adequate as supported by record |
| Whether ALJ properly discounted Plaintiff’s subjective symptom testimony | Buchanan: ALJ mischaracterized treatment records and daily activities; testimony as to fatigue, limited walking/standing, and flashbacks requires credit | Commissioner: ALJ permissibly relied on medical notes showing no acute distress, normal exams, effective conservative treatment, modest imaging, and activities | Granted in part — Court: ALJ mischaracterized daily activities (erroneously stated hiking/extensive activity) and thus the credibility finding is unsupported; remand required |
| Whether ALJ’s Step 5 vocational findings were flawed | Buchanan: VE jobs conflict with RFC and Medical-Vocational Guidelines not addressed | Commissioner: (Not reached by court) | Not addressed — Court remanded on credibility grounds; Step 5 arguments left for further proceedings |
Key Cases Cited
- Tackett v. Apfel, 180 F.3d 1094 (9th Cir.) (standard for reviewing ALJ findings and substantial evidence)
- Smolen v. Chater, 80 F.3d 1273 (9th Cir.) (standards for evaluating claimant symptom testimony)
- Bunnell v. Sullivan, 947 F.2d 341 (9th Cir.) (claimant need not produce objective evidence of symptom itself; ALJ may consider treatment/activities)
- Lester v. Chater, 81 F.3d 821 (9th Cir.) (ALJ must provide specific, clear and convincing reasons to reject claimant testimony)
- Carmickle v. Commissioner, 533 F.3d 1155 (9th Cir.) (ALJ may disbelieve testimony inconsistent with medical record if specific findings made)
- Fair v. Bowen, 885 F.2d 597 (9th Cir.) (daily activities do not necessarily contradict disability; must be transferable to work)
- Orn v. Astrue, 495 F.3d 625 (9th Cir.) (daily activities and credibility analysis limitations)
- Burch v. Barnhart, 400 F.3d 676 (9th Cir.) (ALJ must make specific findings before relying on daily activities to reject testimony)
- Richardson v. Perales, 402 U.S. 389 (U.S.) (definition of substantial evidence)