(SS) Sutton v. Commissioner of Social Security, 1:16-cv-01580

Plaintiff Halonnah Hope Sutton applied for SSI on Jan 29, 2013, alleging disability from scoliosis, cervical degenerative disc disease, osteoarthritis, and chronic pain since Dec 12, 2011; application denied and ALJ found not disabled (May 18, 2015); Appeals Council denied review.
Medical record: thoracic levoscoliosis (~11°), cervical DDD at C5–C6/C6–C7; conservative care included physical therapy (12 sessions), NSAIDs, tramadol, home exercise, and a back brace; imaging and exams showed some objective findings but largely normal strength, gait, and functional testing.
Consultative exam (Dr. Wagner) found normal motor strength, good flexibility, ability to walk/stand and perform ADLs; assessed RFC consistent with medium work (lift 50/25 lbs, frequent stoop/crouch). State consultants found no limitations.
At hearing Plaintiff testified to near-constant severe pain limiting sitting, standing, walking, and requiring lying down daily; she retained daily activities including driving, shopping, cooking, cleaning, biking, and caring for her child.
VE testimony established that jobs existed consistent with ALJ’s RFC; ALJ discounted Plaintiff’s subjective symptom testimony and concluded she could perform past work and other jobs. Court reviewed ALJ decision for substantial evidence and legal error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ gave legally sufficient reasons to discount Sutton’s subjective pain testimony	Sutton: ALJ failed to provide clear and convincing reasons; objective evidence and symptoms support disabling pain and limitations	SSA: ALJ reasonably discounted testimony based on conservative treatment, inconsistent work history, activities exceeding alleged limitations, and objective record	Court: ALJ’s credibility finding upheld — errors in linking specific objective tests were harmless because other clear and convincing reasons (conservative treatment, work history, daily activities) supported discounting testimony

Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (factors ALJ may consider in credibility evaluation)
Brown‑Hunter v. Colvin, 806 F.3d 487 (9th Cir. 2015) (ALJ must link adverse credibility findings to specific evidence)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (clear-and-convincing standard for rejecting subjective testimony)
Morgan v. Comm’r of Soc. Sec. Admin., 169 F.3d 595 (9th Cir. 1999) (improvement with conservative treatment undermines disability claim)
Lingenfelter v. Astrue, 504 F.3d 1028 (9th Cir. 2007) (court must weigh record as a whole; ALJ determination given deference)
Fair v. Bowen, 885 F.2d 597 (9th Cir. 1989) (daily activities may refute claims of total disability)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (ALJ may discredit testimony when activities are transferable to work)
Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155 (9th Cir. 2008) (harmless error doctrine where other valid reasons support ALJ’s credibility decision)
Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (same)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)