Grisham v. Astrue

Summary

The Ninth Circuit affirmed the judgment upholding the denial of Tina Grisham’s application for Social Security disability benefits. The court held that the Administrative Law Judge provided clear and specific reasons for discounting Grisham’s disabling-pain testimony and properly relied on state physicians’ assessments, which were consistent with the treating physician’s opinion and the record.

Holdings

1. When an ALJ disbelieves a disabling-pain allegation based on a demonstrated impairment, the ALJ must make specific findings justifying that decision; the ALJ satisfied that requirement here by identifying clear and specific reasons supported by the record.
2. Opinions of non-treating or non-examining physicians may constitute substantial evidence when consistent with independent clinical findings or other record evidence; the ALJ properly relied on the state physicians' assessments because they were consistent with the treating physician's opinion and the record as a whole.
3. The district court's order affirming the ALJ's decision was properly affirmed because the ALJ's decision was supported by substantial evidence and was not based on legal error.

Questions Presented

1. Whether the ALJ gave legally sufficient reasons for discrediting Grisham's testimony concerning disabling pain.
2. Whether the ALJ properly relied on the opinions of non-treating or non-examining state physicians in determining Grisham's residual functional capacity.
3. Whether the district court properly affirmed the ALJ's decision under the substantial-evidence and legal-error standards.

Disposition

affirmed