(SS) Thompson v. Commissioner of Social Security, 2:12-cv-01850

Thompson sought DIB under Title II; alleged disability beginning Feb 4, 2004.
ALJ decisions denied benefits; Appeals denied review, final decision by ALJ Kwon.
Last insured date is Sept 30, 2009; impairments include depression, plantar fasciitis, pelvic pain.
RFC found as light work with sit/stand option and need for simple, routine tasks.
VE identified potential sedentary jobs, including ticket seller; multiple prior opinions by doctors in record.
This case remanded for further proceedings due to insufficient reasons for rejecting treating physicians’ opinions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the RFC is supported by substantial evidence	Thompson's treating gynecologists’ opinions support disability	RFC reflects substantial evidence including VE input	Partially granted; remand required for proper reasoning on treating opinions
Whether the ALJ properly weighed treating gynecologists’ opinions	ALJ erred by insufficiently crediting Drs. Gonzalez and Baldonado	ALJ appropriately weighed opinions within record	Remand required for specific, legitimate reasons for discounting treating opinions
Whether credibility and reliability findings were properly articulated	Inconsistent work-history statements undermine credibility	ALJ credibility findings supported by record	Credibility analysis upheld but remand urged for proper evaluation of opinions
Whether sleep disturbances were properly considered in RFC	Sleep issues tied to pelvic pain should influence RFC	Sleep evidence not essential after credibility findings	No reversible error; sleep issues not separately required where credibility supported impairment assessment
Whether the case should be remanded for further proceedings	Improper rejection of treating opinions warrants reversal	Record supports decision pending further development	Remanded for further proceedings to address treating opinions and RFC specifics

Lester v. Chater, 81 F.3d 821 (9th Cir. 1995) (treating physician opinions require clear and convincing reasons to reject)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (credibility and internal inconsistencies affect disability findings)
Cotton v. Bowen, 799 F.2d 1403 (9th Cir. 1986) (Cotton test for credibility with objective impairment and lack of malingering evidence)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (consideration of symptoms and medical evidence in RFC and credibility)
Connett v. Barnhart, 340 F.3d 871 (9th Cir. 2003) (remand when RFC and opinions require clearer articulation)
Stout v. Comm'r, Soc. Sec. Admin., 454 F.3d 1050 (9th Cir. 2006) (harmless-error rule; review of ALJ reasons must be grounded in decision)
Weetman v. Sullivan, 877 F.2d 20 (9th Cir. 1989) (weight afforded to pain testimony and credibility)