(SS) Singh v. Commissioner of Social Security, 1:16-cv-01709

Plaintiff Sandra Singh applied for Disability Insurance Benefits alleging disability from October 18, 2012, based primarily on left-arm lymphedema following partial mastectomy, with recurrent cellulitis; administrative denial was appealed to district court after exhaustion.
ALJ Cynthia Floyd found Singh’s left-arm lymphedema (with frequent cellulitis) severe but other conditions (hypertension, restless leg, osteopenia, depression) nonsevere, and concluded no listed impairment was met.
ALJ assessed an RFC for light work with limits: lift/carry 20 lbs occasionally, 10 lbs frequently; stand/walk/sit 6 hours/8-hour day; occasional ladders/overhead left reaching; frequent crawling, frequent hand/finger use.
ALJ relied on consultative examiner Dr. Rustom Damania (reduced left grip, left-side limits) and two state agency reviewers; plaintiff argued ALJ misstated and failed to adopt some of Dr. Damania’s left-arm limitations (reaching/pushing/pulling and lower left-side lifting limits).
Vocational expert testified that more restrictive left-arm limits (10 lbs occasional/less than 10 frequent and only occasional left extension) would preclude plaintiff’s past work.
District court reviewed the record and found the ALJ’s misstatements regarding Dr. Damania were harmless because the RFC and reasoning were supported by other medical opinions, objective findings, treatment history, and plaintiff’s activities of daily living.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ mischaracterized Dr. Damania’s finding on left-arm reaching/pushing/pulling	ALJ wrongly stated Dr. Damania found frequent left reaching/pushing/pulling when he limited to no frequent use	ALJ erred but the RFC still adequately limited left-arm use and the error is harmless	Error was harmless; ALJ limited to occasional use which aligns with no-frequent restriction
Whether ALJ failed to incorporate Dr. Damania’s left-arm lifting/carrying limits into RFC	ALJ gave Damania "generous weight" but did not adopt his left-side limit of 10 lbs occasional/ <10 lbs frequent	Although misstated, ALJ relied on other state consultants and record evidence to support a light work RFC	Error was harmless; other medical opinions and record support ALJ’s light-RFC finding
Whether ALJ provided legally adequate reasons for rejecting more restrictive limitations	ALJ did not expressly explain rejecting Damania’s lifting limits	Defendant: ALJ relied on state reviewers, objective findings, conservative treatment, and plaintiff’s ADLs	Held: Specific and legitimate reasons implicit in decision suffice because errors were inconsequential to nondisability result
Whether the ALJ’s RFC is supported by substantial evidence	RFC inconsistent with parts of consultative report according to Singh	RFC supported by state agency opinions, objective exams, treatment history, and activities	Court: RFC supported by substantial evidence; denial of benefits upheld

Carmickle v. Comm'r of Soc. Sec., 533 F.3d 1155 (9th Cir. 2008) (harmless error standard for ALJ mistakes in credibility/medical findings)
Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (definition and scope of substantial evidence review)
Lester v. Chater, 81 F.3d 821 (9th Cir. 1996) (weight to be given to treating/examining physician opinions)
Hoopai v. Astrue, 499 F.3d 1071 (9th Cir. 2007) (standard for reviewing ALJ findings)
Trevizo v. Berryhill, 871 F.3d 664 (9th Cir. 2017) (standard for rejecting uncontroverted examining opinions)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (ALJ’s duty to reconcile conflicting medical opinions)
Ghanim v. Colvin, 763 F.3d 1154 (9th Cir. 2014) (requirements for discounting contradicted medical opinions)
Morgan v. Comm'r of Soc. Sec. Admin., 169 F.3d 595 (9th Cir. 1999) (examining physician opinions not conclusive on disability)
Magallanes v. Bowen, 881 F.2d 747 (9th Cir. 1989) (non-examining opinions may constitute substantial evidence when consistent with record)