Timothy Saenz v. Nancy Berryhill
686 F. App'x 397
| 9th Cir. | 2017Background
- Timothy Saenz appealed the district court’s affirmation of the Commissioner’s denial of his Title II disability insurance benefits claim.
- The ALJ partially rejected Saenz’s symptom testimony, citing inconsistent statements about alcohol use and lack of supporting objective medical evidence.
- Examining physician Dr. Donald Ramsthel gave an opinion of greater limitation, which the ALJ gave very little weight because it relied heavily on Saenz’s subjective reports and lacked contemporaneous clinical support.
- The ALJ gave only some weight to lay witness statements (from Idas Saenz and Jessica Fox), finding they were either duplicative of the residual functional capacity (RFC) or unsupported by medical evidence.
- A vocational expert (VE) testified that Saenz could perform jobs existing in significant numbers; the ALJ relied on that testimony to find Saenz not disabled.
- The Ninth Circuit reviewed the ALJ’s credibility, medical-opinion, lay-witness, and VE reliance issues de novo and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ’s rejection of claimant testimony | Saenz: ALJ improperly discredited his pain and limitation testimony | Comm’r: Inconsistencies about alcohol use and lack of objective medical support justified partial rejection | Affirmed — ALJ gave clear and convincing reasons (inconsistent alcohol statements; limited objective support) |
| Weight given to examining physician (Ramsthel) | Saenz: Dr. Ramsthel’s opinion showed greater functional limits and should be credited | Comm’r: Opinion relied on claimant’s subjective complaints and lacked contemporaneous clinical support | Affirmed — ALJ offered specific, legitimate reasons to give the contradicted opinion very little weight |
| Weight to lay witness testimony | Saenz: Lay witnesses corroborate limitations | Comm’r: Lay statements were accounted for in RFC or unsupported by medical evidence | Affirmed — ALJ provided germane reasons for discounting lay testimony |
| Reliance on vocational expert testimony | Saenz: VE testimony insufficient or inadequate foundation | Comm’r: VE’s expertise on job existence and characteristics is sufficient | Affirmed — VE testimony provided adequate foundation to establish jobs existed in significant numbers |
Key Cases Cited
- Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (standard for reviewing ALJ findings and credibility analysis)
- Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (inconsistent statements about alcohol use can support rejection of testimony)
- Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (lack of objective medical evidence is a factor in credibility determinations)
- Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (ALJ need not accept contradicted medical opinion inadequately supported by clinical findings)
- Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (ALJ may reject medical opinions based on claimant self-reports when those reports are discounted)
- Johnson v. Shalala, 60 F.3d 1428 (9th Cir. 1995) (VE expertise about job existence and characteristics can overcome DOT presumption)