KAMINSKI v. KIJAKAZI (2021)

United States Court of Appeals, Ninth Circuit.2021-08-17No. No. 20-16775

Summary · law.co

Holding. The court affirmed the administrative law judge's denial of disability benefits, finding that the decision was supported by substantial evidence and involved no legal error.

John Kaminski sought disability insurance benefits under Social Security law but was denied by an administrative law judge. The district court affirmed that denial, and Kaminski appealed. The appellate court reviewed the case and found no errors in how the administrative law judge evaluated the medical evidence or determined Kaminski's functional limitations.

The court addressed three main challenges Kaminski raised. First, the judge properly weighted a psychiatrist's opinion that conflicted with other medical records and evidence of successful treatment. Second, treatment notes from other doctors and a social worker documenting Kaminski's conditions were not required to be formally addressed because they did not assess the severity of his impairments or resulting functional limitations. Third, Kaminski failed to specify what additional mental limitations should have been included in the judge's functional capacity assessment beyond what was already considered.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Weight given to conflicting medical opinions in disability determinations
Whether treatment notes lacking functional capacity assessments must be formally addressed
Adequacy of residual functional capacity findings when claimant fails to identify omitted limitations

Procedural posture

Kaminski appealed the district court's affirmance of the Social Security Administration's denial of his Title II disability benefits application.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Claimant John Kaminski appeals from the district courts order affirming the Commissioners denial of his application for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. § 423. We have jurisdiction under 42 U.S.C. § 405(g) and 28 U.S.C. § 1291. We review the district courts order de novo and reverse only if the Administrative Law Judges (ALJ) decision was not supported by substantial evidence or was based on legal error. Larson v. Saul, 967 F.3d 914, 922 (9th Cir. 2020). We affirm.

1. The ALJ rejected consultative examining psychiatrist Charles DeBattista, M.D.’s opinion that Kaminski had marked and moderate-to-marked limitations in the relevant areas because these conclusions conflicted with other medical evidence and with the documented effectiveness of Kaminskis mental health treatment. On the record presented in this case, any argument that the ALJ erred by giving Dr. DeBattistas opinion only some weight fails. See 20 C.F.R. § 404.1527(c)(3), (4); Revels v. Berryhill, 874 F.3d 648, 654 (9th Cir. 2017).

2. Contrary to Kaminskis assertions, the ALJ did not err by not addressing treating psychiatrists Cynthia Hunt, M.D. and Charles Edwards, M.D.’s treatment notes and social worker Susan Valencias documentation of his severe mental impairments when determining that Kaminski was not disabled. Because the treating psychiatrists’ treatment notes offered no opinion about the severity of Kaminskis mental impairments or any functional limitations that those impairments caused, they are not medical opinions that the ALJ must address in its disability determination. See 20 C.F.R. §§ 404.1527(a)(1), 416.927(a)(1); Turner v. Commr of Soc. Sec., 613 F.3d 1217, 1223–24 (9th Cir. 2010). Similarly, Ms. Valencias documentation of Kaminskis auditory hallucinations, schizophrenia, and anxiety, without any assessment of their severity or functional limitations, is insufficient proof of disability. See Matthews v. Shalala, 10 F.3d 678, 680 (9th Cir. 1993) (noting “[t]he mere existence of an impairment is insufficient proof of a disability”).

3. Kaminskis argument that substantial evidence does not support the ALJs residual functional capacity (RFC) finding fails because Kaminski does not specify what mental limitations, besides those for which the ALJ had already accounted in the RFC, follow from the impairments that he claims the ALJ failed to include in the RFC determination. See Valentine v. Commr of Soc. Sec. Admin., 574 F.3d 685, 692 n.2 . (9th Cir. 2009).

AFFIRMED.