Steven Ahearn v. Andrew Saul, 988 F.3d 1111

Steven Ahearn applied for Supplemental Security Income (SSI) claiming disability since October 1, 2010; an ALJ denied benefits and that decision became final on December 16, 2014.
Ahearn filed a second SSI application two months later and submitted new evidence; the ALJ considered a res judicata–based presumption of non-disability but also performed a full five-step disability analysis.
The ALJ found Ahearn’s RFC allowed past relevant work (janitor, home care attendant) and other work, and denied benefits. The district court affirmed; Ahearn appealed.
The ALJ discounted Ahearn’s symptom testimony (citing medical records, prior work history, and daily activities) and gave limited or no weight to examining psychologists Bates, Ruddell, and Wingate for reasons including remoteness, inconsistency with the record, and apparent secondary-gain influences.
The ALJ gave greater weight to non-examining state-agency psychologists (Kraft and Donahue) whose opinions were consistent with the record; the Ninth Circuit held the ALJ’s findings were supported by substantial evidence and affirmed.
The opinion emphasizes the correct standard of review in SSI cases: the substantial-evidence standard (not the immigration compelled-conclusion formulation from Elias-Zacarias).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review	Ahearn challenged the denial under the substantial-evidence standard	Gov't urged that Elias-Zacarias compelled-conclusion language governs review	Ninth Circuit: SSI review uses substantial-evidence standard; Elias-Zacarias standard is for immigration and inapplicable
Credibility of claimant testimony	ALJ improperly discounted Ahearn’s reported limitations	ALJ said testimony conflicted with medical records, work history, daily activities	Held: ALJ gave specific, clear, convincing reasons; decision supported by substantial evidence
Weight to examining psychologists	ALJ erred by discounting Bates, Ruddell, Wingate assessments	ALJ found Bates remote; Ruddell/Wingate inconsistent with record or influenced by secondary gain; relied on state-agency reviewers	Held: No error; ALJ permissibly assigned limited/no weight and relied on supported state-agency opinions
Res judicata / presumption of non-disability	ALJ applied presumption though Ahearn was unrepresented at first proceeding	ALJ/district court argued any presumption error was harmless because ALJ independently evaluated the record	Held: Error to apply presumption, but harmless because ALJ conducted independent review; affirmed

I.N.S. v. Elias-Zacarias, 502 U.S. 478 (1992) (immigration case discussing compelled-conclusion phrasing)
Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (Supreme Court explanation of the substantial-evidence standard in administrative review)
Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (definition and application of substantial-evidence review in disability cases)
Mayes v. Massanari, 276 F.3d 453 (9th Cir. 2001) (requirement to weigh supporting and detracting evidence in the record)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (two-step credibility analysis for symptom testimony)
Smolen v. Chater, 80 F.3d 1273 (9th Cir. 1996) (ALJ must give clear, convincing reasons to reject testimony absent malingering)
Lester v. Chater, 81 F.3d 821 (9th Cir. 1995) (requirement to provide specific, cogent reasons to discount claimant testimony)
Andrews v. Shalala, 53 F.3d 1035 (9th Cir. 1995) (ALJ responsible for resolving medical conflicts; non-examining opinion may be relied on if consistent with record)
Carmickle v. Comm'r, Soc. Sec. Admin., 533 F.3d 1155 (9th Cir. 2008) (medical opinions predating alleged onset have limited relevance)
Legacy Emanuel Hosp. & Health Ctr. v. Shalala, 97 F.3d 1261 (9th Cir. 1996) (different statutory language yields different standards of review)