(SS) Senstad v. Commissioner of Social Security
2:23-cv-02930
E.D. Cal.Jun 25, 2025Background
- Amy L. Senstad sought judicial review of a denial of her application for disability insurance benefits and supplemental security income by the Commissioner of Social Security.
- The administrative law judge (ALJ) determined Senstad was not disabled, finding her testimony about her symptoms not credible and concluding she could perform work as a display designer.
- The magistrate judge recommended affirming the ALJ's decision, finding the ALJ gave valid reasons for rejecting Senstad's testimony.
- Senstad objected, arguing the ALJ failed to cite specific, clear, and convincing reasons for discounting her reports of pain and limitation.
- The district court conducted a de novo review, finding in favor of Senstad and declining to adopt the magistrate judge's recommendation.
- The court remanded the case to the Commissioner for further proceedings, instructing the ALJ to provide proper reasoning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ provide specific, clear and convincing reasons for rejecting Senstad's subjective testimony about her symptoms? | ALJ failed to specifically identify what testimony is undermined by the evidence; only gave boilerplate reasons | ALJ sufficiently relied on inconsistencies between testimony, medical record, treatment history, daily activities | The ALJ did not provide specific, clear and convincing reasons; error was not harmless |
| Was mere summarization of medical evidence, without connecting it to specific testimony, sufficient to dismiss Senstad's credibility? | ALJ just summarized evidence, didn't show how it undercut precise statements | ALJ is not required to use "magic words" or link every bit of medical evidence to every part of testimony | Summarization without specificity is insufficient under Ninth Circuit precedent |
| Can the court uphold the ALJ's determination by independently identifying inconsistencies in the record? | Only ALJ’s articulated inconsistencies can be reviewed, not new ones found by reviewing courts | District court or defendant can identify inconsistencies in the record to justify ALJ’s result | Court cannot affirm on grounds not articulated by ALJ; reversal required |
| Is remand for further proceedings the proper remedy? | Requests remand for a new hearing | No objection stated | Case remanded to the agency for further proceedings |
Key Cases Cited
- Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (sets out two-step process and high standard for rejecting subjective symptom testimony)
- Brown-Hunter v. Colvin, 806 F.3d 487 (9th Cir. 2015) (ALJ must specify what testimony is not credible and why)
- Treichler v. Comm’r of Soc. Sec. Admin., 775 F.3d 1090 (9th Cir. 2014) (boilerplate language is not specific, clear, and convincing reasoning)
- Lambert v. Saul, 980 F.3d 1266 (9th Cir. 2020) (requires ALJ to tie evidence to specific disputed testimony)
- Ferguson v. O’Malley, 95 F.4th 1194 (9th Cir. 2024) (clarifies standards for subjective symptom testimony assessment)