Steele v. Commissioner Social Security Administration, 6:13-cv-02286

Edward C. Steele, Jr. applied for DIB and SSI on July 26, 2010, alleging disability from February 17, 2010, for physical (testicular pain, varicocele, pneumonia/empyema, enuresis) and mental (depression, PTSD, substance dependence) impairments.
ALJ held a hearing, found severe impairments, assessed an RFC for less-than-full-range light work with significant social and task limitations, and denied benefits at step five based on jobs identified by a VE. Appeals Council denied review.
Steele challenged the ALJ’s credibility finding, the ALJ’s evaluation of treating psychiatrist Robert Vandiver, M.D., and examining psychiatrist Gale Smolen, M.D., and the step-five determination.
District court reviewed the record under the substantial-evidence standard and found errors in the ALJ’s evaluation of treating psychiatrist Dr. Vandiver and in failing to reconcile conflicting mental-health opinions in light of later suicide attempts and hospitalizations.
Because of those errors and unresolved conflicts in the record, the court reversed and remanded for further administrative proceedings, including a new psychodiagnostic evaluation and a new hearing (with new vocational testimony if needed).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly evaluated Steele's credibility	Steele: ALJ failed to give clear and convincing reasons to discount his symptom testimony	Commissioner: ALJ properly relied on inconsistencies between testimony, reported activities, and objective evidence	Held: ALJ gave clear and convincing reasons (inconsistent statements, activities, lack of objective support); credibility finding upheld
Whether the ALJ properly weighed treating psychiatrist Dr. Vandiver's opinion	Steele: ALJ failed to provide specific and legitimate (or clear and convincing) reasons to reject Vandiver's opinion about severe irritability and inability to work near others	Commissioner: ALJ discounted Vandiver based on inconsistency with Steele's testimony and medical records	Held: ALJ erred — inconsistency with testimony is supported, but the ALJ’s contrary-treatment-record rationale was not supported; discounting Vandiver was improper without adequate reasons
Whether the ALJ properly resolved conflicts among mental-health opinions (Vandiver vs. Smolen/Anderson)	Steele: ALJ failed to reconcile Vandiver’s later, more restrictive opinion with earlier opinions and post-2011 hospitalizations	Commissioner: ALJ relied on earlier examining and nonexamining opinions and credibility findings	Held: ALJ failed to adequately resolve conflicting opinions in light of Steele's 2011–2012 suicide attempts and hospitalizations; remand required for further development

Bowen v. Yuckert, 482 U.S. 137 (U.S. 1987) (establishes SSA five-step sequential evaluation framework)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (two-step test for assessing symptom testimony and requirement that symptoms be consistent with objective evidence and other record evidence)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (standards for crediting testimony, remand for further proceedings vs. benefits, and obligation to provide reasoned analysis when rejecting medical opinions)
Ghanim v. Colvin, 763 F.3d 1154 (9th Cir. 2014) (ALJ must provide specific, clear reasons when discrediting claimant testimony; may consider inconsistencies and objective evidence)
Carmickle v. Commissioner Social Security Admin., 533 F.3d 1155 (9th Cir. 2008) (treating vs. examining opinion weight and proper bases for rejecting claimant testimony)