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DICKSON v. SAUL (2021)

United States Court of Appeals, Ninth Circuit.2021-02-24No. No. 19-17215

Summary

Holding. The district court's affirmance of the Commissioner's denial of disability benefits was affirmed because the ALJ's decision to reject the treating physicians' opinions, credit non-treating physicians' opinions, and discount the claimant's symptom testimony were supported by substantial evidence and contained no legal error.

Marlene Dickson sought Social Security disability insurance benefits under Title II of the Social Security Act, but an administrative law judge denied her application. The district court affirmed that denial, and Dickson appealed. The appellate court reviewed whether the ALJ properly evaluated medical evidence and Dickson's testimony about her symptoms and limitations.

The court found no legal error in the ALJ's handling of the medical opinions. Although treating physicians' opinions ordinarily receive controlling weight, the ALJ properly rejected the opinions of Dickson's treating physicians because they contradicted other medical evidence and the physicians' own clinical notes, supported by substantial evidence in the record. The ALJ appropriately gave greater weight to non-treating physicians' opinions, including those of Dr. Karen Mansfield-Blair and examining physicians, because their findings aligned with the medical record and Dickson's documented daily activities.

The court also upheld the ALJ's rejection of Dickson's testimony regarding symptom severity. The ALJ identified a contradiction between Dickson's described daily activities and her claims of disabling symptoms and functional limitations. This inconsistency provided sufficient grounds to discount her symptom testimony under established precedent.

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

Key issues

  • Weight to be given treating physicians' opinions versus other medical evidence
  • Proper grounds for rejecting a claimant's symptom testimony
  • Consistency between documented daily activities and claimed functional limitations

Procedural posture

The claimant appealed the district court's affirmance of the Commissioner's denial of her disability insurance benefits application.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

MEMORANDUM *

Claimant Marlene Dickson appeals from the district courts decision affirming the Commissioners denial of her application for disability insurance benefits under Title II of the Social Security Act. We have jurisdiction under 28 U.S.C. § 1291. “We review the district courts order affirming the ALJs denial of social security benefits de novo, and will disturb the denial of benefits only if the decision contains legal error or is not supported by substantial evidence.” Ford v. Saul, 950 F.3d 1141, 1153–54 (9th Cir. 2020) (internal quotation marks omitted) (quoting Tommasetti v. Astrue, 533 F.3d 1035, 1038 (9th Cir. 2008)).

The Administrative Law Judge (ALJ) did not err in rejecting the assessments of Dicksons treating physicians, Drs. Laura Sherman and Loren Froelich. While a treating physicians opinion generally receives “controlling weight,” see 20 C.F.R. § 404.1527(c)(2), “if the treating doctors opinion is contradicted by another doctor, the ALJ may discount the treating physicians opinion by giving specific and legitimate reasons that are supported by substantial evidence in the record,” Ford, 950 F.3d at 1154 (internal quotation marks and citation omitted). The ALJ offered specific and legitimate reasons to reject Dicksons treating physicians’ opinions. Namely, the ALJ assigned those physicians’ opinions little weight because they were inconsistent with the medical evidence and the physicians’ own notes and this reasoning is supported by substantial evidence in the record.

Additionally, the ALJ did not err in assigning greater weight to the non-treating physicians’ opinions. The ALJ assigned great weight to Dr. Karen Mansfield-Blairs opinion because it was consistent with the medical evidence and Dicksons daily activities. See 20 C.F.R. § 404.1527(c)(4). The ALJ also assigned partial weight to the opinions of examining physicians Drs. Neil Stafford and An Nguyen and the non-examining physician Dr. Elliot Salk because their findings of mild impairments were consistent with the record. Because these conclusions are supported by substantial evidence, the ALJ did not err in assessing these medical opinions.

Finally, the ALJ did not err in discounting Dicksons symptom testimony. If a claimant has shown that an impairment “could reasonably be expected to produce the pain or other symptoms alleged,” the ALJ may reject “testimony about the severity of her symptoms only by offering specific, clear and convincing reasons for doing so.” Lingenfelter v. Astrue, 504 F.3d 1028, 1036 (9th Cir. 2007) (citations omitted). The ALJ concluded that Dicksons described daily activities were inconsistent with her allegations of disabling symptoms and limitations. Because a contradiction between daily activities and alleged limitations is a sufficient basis to reject Dicksons testimony, see Molina v. Astrue, 674 F.3d 1104, 1113 (9th Cir. 2012), we find no error.

AFFIRMED.