(SS) Love v. Commissioner of Social Security, 1:14-cv-01802

Plaintiff Estela Love applied for SSDI/DIB in July 2011 alleging bilateral knee pain, obesity, hypertension, diabetes and depression; application denied and ALJ denied benefits after an April 2013 hearing; Appeals Council denied review.
Objective imaging: left knee x‑ray showed moderate medial compartment degenerative changes; left MRI showed medial meniscal degenerative tear and patellar chondromalacia; right MRI showed extensive lateral meniscal tear, patellar chondromalacia, effusion and osteochondral defect.
Consultative exams: internist found ability to lift up to 20 lbs occasionally, stand/walk 4–6 hours, sit up to 6 hours; psychiatrist found depressive disorder and opined Plaintiff could perform simple job instructions but not complex ones.
Hearing testimony: Plaintiff (limited education) reported standing 20–30 minutes, walking 10–15 steps, sitting 20–30 minutes, difficulty using hands, and significant depression; daughters assist with chores.
ALJ found severe impairments but concluded Plaintiff retained RFC for a limited range of light work with postural restrictions and marked limitations for detailed/complex instructions; ALJ found Plaintiff could perform past work as a maid and denied benefits.
District court reversed and remanded, holding the ALJ erred in discounting Plaintiff’s symptom testimony because the ALJ relied primarily on lack of objective corroboration and failed to give clear and convincing reasons.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ gave legally sufficient reasons to reject Plaintiff's subjective symptom testimony	Love: ALJ rejected testimony solely because it was inconsistent with objective medical evidence, which is insufficient	Colvin: ALJ relied on inconsistencies with treatment notes, response to medication, and daily activities to discount credibility	Court: Reversed — ALJ relied primarily on lack of objective support and failed to give clear and convincing reasons; remand required
Whether improvement with medication justified adverse credibility finding	Love: ALJ did not show medication produced satisfactory symptom control	Colvin: Medication/treated impairments supports discounting testimony	Court: Rejected as stated — mere recitation that plaintiff is medicated is not a specific finding that symptoms were controlled
Whether daily activities supported discounting testimony	Love: ALJ did not connect specific activities to the challenged symptom statements	Colvin: Daily activities are valid factor	Court: ALJ's brief reference was insufficiently specific and did not build a logical bridge
Remedy — credit-as-true vs. remand for further proceedings	Love: Requested benefits award	Colvin: Argued more proceedings appropriate	Court: Remanded for further proceedings to reassess credibility and reassess steps 4–5 (remand, not award)

Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)
Bunnell v. Sullivan, 947 F.2d 341 (9th Cir. 1991) (objective evidence alone insufficient to reject pain testimony)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (two‑step analysis for evaluating subjective symptom testimony; clear and convincing standard)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (ALJ may consider daily activities among other factors)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (remand for further proceedings appropriate where credit‑as‑true rule not compelled)
Orn v. Astrue, 495 F.3d 625 (9th Cir. 2007) (court may not accept post hoc rationalizations for ALJ's decision)