Travis Coleman v. Andrew Saul, 979 F.3d 751

Background:

Coleman alleged disability from November 5, 2013 due to spine/neck pain; treated by multiple providers and underwent C5–C6 anterior discectomy in May 2015.
Treating providers (e.g., Dr. Foster, NP Schwarzkopf, Dr. Jackson) gave opinions of severe limitations; some clinicians (Dr. Atteberry, Dr. Stoilova) found normal strength/gait and MRIs that did not explain his pain.
Psychological evaluator Dr. Schneider diagnosed "pain disorder associated with psychological and physical factors" but noted diagnostic uncertainty and relied on Coleman’s self-reports.
Multiple emergency‑room visits generated an information‑exchange alert showing numerous opioid prescriptions from multiple providers; ER staff refused additional opioids and observed pain‑inconsistent behavior on some exams.
ALJ found severe impairments of lumbar degenerative disc disease and post‑cervical fusion, assessed RFC (sedentary through May 2016, light thereafter), and concluded Coleman could perform his past work (alternatively other work); district court affirmed and Ninth Circuit affirmed.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly discounted Coleman's subjective pain testimony	ALJ erred; testimony of severe, persistent pain should be credited	ALJ gave clear and convincing reasons (drug‑seeking behavior, observed pain‑inconsistent conduct)	Affirmed: ALJ permissibly discounted testimony for clear and convincing reasons
Whether ALJ erred in rejecting/discounting treating and other medical opinions	ALJ improperly rejected treating physicians, psychologist, and NPs who found severe limits	ALJ gave specific and legitimate reasons: contradictions in the record, normal exams, imaging not supporting severe limits, reliance on discredited self‑reports	Affirmed: ALJ provided legally sufficient reasons to discount those opinions
Whether ALJ erred by not listing pain disorder as a severe impairment at Step Two	Pain disorder diagnosed by Dr. Schneider should be a severe impairment	Dr. Schneider’s diagnosis relied on Coleman’s self‑reports and was equivocal; objective evidence did not support the claimed severity	Affirmed: Substantial evidence supported exclusion of pain disorder as a severe impairment
Whether RFC and step‑4/5 findings were unsupported by the record	RFC (sedentary then light) and step‑4 finding (can perform past work) were inconsistent with records of severe limitation	ALJ’s RFC based on supported medical evidence and vocational testimony; alternative jobs identified	Affirmed: ALJ’s RFC and resulting disability conclusions supported by substantial evidence

Key Cases Cited

Molina v. Astrue, 674 F.3d 1104 (9th Cir. 2012) (standard of review and framework for evaluating ALJ findings)
Andrews v. Shalala, 53 F.3d 1035 (9th Cir. 1995) (definition of substantial evidence)
Fair v. Bowen, 885 F.2d 597 (9th Cir. 1989) (importance of credibility assessment in excess‑pain cases)
Reddick v. Chater, 157 F.3d 715 (9th Cir. 1998) (objective evidence cannot be sole basis to discredit pain testimony)
Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (ALJ must give clear and convincing reasons to reject subjective pain testimony)
Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (treating‑physician rule requiring clear and convincing reasons to reject uncontradicted opinions)
Edlund v. Massanari, 253 F.3d 1152 (9th Cir. 2001) (ALJ may reject treating opinion contradicted by other exam findings with specific and legitimate reasons)
Tommasetti v. Astrue, 533 F.3d 1035 (9th Cir. 2008) (ALJ may reject physician opinion based largely on properly discounted self‑reports)
Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190 (9th Cir. 2004) (ALJ may discredit treating opinions that are conclusory or unsupported)
Burch v. Barnhart, 400 F.3d 676 (9th Cir. 2005) (review is deferential where evidence admits multiple rational interpretations)
Britton v. Colvin, 787 F.3d 1011 (9th Cir. 2015) (nurse practitioners were not "acceptable medical sources" for claims filed during the period at issue)