Steven Ahearn v. Carolyn Colvin, 23-35572

Steven T. Ahearn appealed the denial of his application for supplemental security income (SSI) under Title XVI of the Social Security Act.
This was Ahearn's third application; previous applications had been denied and not overturned on appeal.
The administrative law judge (ALJ) found Ahearn not disabled based on a review of the relevant evidence, including medical records, consultant evaluations, and lay testimony.
The ALJ gave little weight to older medical opinions that predated the alleged onset date of May 27, 2020, focusing on evidence from the relevant period.
The ALJ discounted some subjective testimonies and lay witness accounts due to inconsistencies and evidence of Ahearn's ability to perform daily activities.
The district court affirmed the ALJ’s decision, and Ahearn appealed to the Ninth Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consideration of pre-onset medical evidence	ALJ erred by ignoring limiting pre-onset opinions	These opinions were irrelevant to the period in question	No error—pre-onset opinions were not relevant
Evaluation of medical opinion (Wilkinson 2020)	ALJ improperly rejected or undervalued this opinion	ALJ’s partial acceptance was based on consistency with record	Supported by substantial evidence—no error
Reliance on non-examining psychologists	ALJ wrongfully favored state psychologists over treating physicians	State agency psychologists’ findings were valid and consistent	Permissible for ALJ to rely on these findings
Subjective symptom and lay testimony assessment	ALJ failed to properly weigh plaintiff’s and lay testimony	ALJ gave clear reasons for discounting based on inconsistencies	ALJ’s assessment was sufficiently justified

Howard ex rel. Wolff v. Barnhart, 341 F.3d 1006 (9th Cir. 2003) (ALJ does not need to discuss every piece of evidence in the record)
Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155 (9th Cir. 2008) (Medical opinions predating onset are of limited relevance)
Kitchen v. Kijakazi, 82 F.4th 732 (9th Cir. 2023) (ALJ may discount opinions inconsistent with record)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (ALJ may reject medical opinion inconsistent with medical records)
Ford v. Saul, 950 F.3d 1141 (9th Cir. 2020) (ALJ may reject treating opinions based on contradictory state agency opinions)
Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (ALJ may discount subjective testimony inconsistent with daily activities)
Moncada v. Chater, 60 F.3d 521 (9th Cir. 1995) (ALJ may discredit subjective testimony based on functional evidence)
Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (ALJ can discount medical and subjective evidence with clear, convincing reasons)
Valentine v. Comm’r Soc. Sec. Admin., 574 F.3d 685 (9th Cir. 2009) (Germane reasons to claimant's testimony also apply to similar lay testimony)
Stubbs-Danielson v. Astrue, 539 F.3d 1169 (9th Cir. 2008) (ALJ's hypothetical to vocational expert adequate if based on supported RFC)