Trego v. Astrue

Summary

The Ninth Circuit reversed the district court’s grant of summary judgment upholding the denial of Disability Insurance Benefits and Supplemental Security Income to Wilfred Trego. The court held that the ALJ inadequately evaluated the treating and non-examining physicians’ opinions and gave legally insufficient reasons for rejecting Trego’s testimony about the severity of his back pain. Because the vocational expert testified that a person needing to lie down for two hours during a workday could not perform any work, the case was remanded for calculation of benefits.

Holdings

1. The ALJ did not satisfy the requirement to provide a detailed and thorough explanation of the facts and conflicting clinical evidence before relying on the non-examining physician's opinion over the treating physician's contradicted opinion.
2. The ALJ failed to provide clear and convincing reasons supported by the record for rejecting Trego's testimony about the severity of his back pain and resulting limitations.
3. Further proceedings concerning Trego's disability status were not warranted; the case was remanded for calculation of benefits.

Questions Presented

1. Whether the ALJ improperly relied on a non-examining physician's unexplained opinion over the contradicted opinion of Trego's treating physician.
2. Whether the ALJ gave legally sufficient clear and convincing reasons for rejecting Trego's testimony concerning the severity of his back pain and functional limitations.
3. Whether the record required remand for further administrative proceedings or calculation of benefits.

Disposition

reversed_and_remanded