JACKSON v. SAUL (2021)

United States Court of Appeals, Ninth Circuit.2021-04-08No. No. 18-17442

Summary · law.co

Holding. The court affirmed the district court's judgment, finding that substantial evidence supported the ALJ's determination that Jackson's testimony about his physical condition was not entirely credible and that the ALJ properly applied the legal standard for evaluating credibility.

Rodney Jackson appealed the denial of his applications for disability insurance benefits and supplemental security income. The district court had upheld an administrative law judge's decision rejecting his claim. On appeal, Jackson challenged the credibility determination regarding his reported physical symptoms and functional limitations.

The court examined whether substantial evidence supported the ALJ's finding that Jackson's account of his symptoms lacked full credibility. The ALJ had conducted the required credibility analysis and documented specific reasons for discounting Jackson's testimony. Those reasons included inconsistencies between Jackson's statements about his back pain and limitations compared to medical records and an examining physician's findings. Additionally, the ALJ noted that Jackson's actual course of treatment was minimal and conservative, and he failed to pursue recommended follow-up care.

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

Key issues

Credibility of claimant's testimony regarding physical symptoms and limitations
Consistency between claimant's statements and medical evidence
Relevance of minimal treatment and failure to follow prescribed care

Procedural posture

Jackson appealed the district court's affirmance of the Social Security Commissioner's denial of his disability benefits applications.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Rodney Jackson appeals the district courts judgment affirming the Commissioner of Social Securitys denial of his application for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. We have jurisdiction under 28 U.S.C. § 1291 and 42 U.S.C. § 405(g). We review the district courts affirmance of the administrative law judges (“ALJ”) decision de novo and will reverse only if the ALJs decision is not supported by substantial evidence or if the ALJ applied the wrong legal standard. Molina v. Astrue, 674 F.3d 1104, 1110 (9th Cir. 2012), superseded by regulation on other grounds. We affirm the district courts judgment.

Substantial evidence supports the ALJs finding that Jacksons testimony regarding his physical symptoms and limitations was “not entirely credible.” The ALJ performed the required two-step analysis and provided “specific, clear and convincing reasons” for her finding. Tommasetti v. Astrue, 533 F.3d 1035, 1039 (9th Cir. 2008) (quoting Smolen v. Chater, 80 F.3d 1273, 1281 (9th Cir. 1996)). The ALJ properly relied on contradictions between the medical record, including an examining doctors opinion, and Jacksons testimony about his back pain and limitations. See Rollins v. Massanari, 261 F.3d 853, 857 (9th Cir. 2001). The ALJ also properly considered Jacksons course of treatment and failure to follow up with prescribed treatment. See Molina, 674 F.3d at 1113–14 (ALJ may consider claimants failure to seek treatment or to follow a prescribed course of treatment); Meanel v. Apfel, 172 F.3d 1111, 1114 (9th Cir. 1999) (subjective pain complaints properly discredited where claimant received “minimal” and “conservative” treatment).

AFFIRMED.