Summary
The Ninth Circuit reversed and remanded a district court judgment affirming the denial of disability insurance benefits. The court held that the ALJ failed to provide specific and legitimate reasons for rejecting the opinions of Wolfram’s treating physicians and constructed an incomplete hypothetical for the vocational expert by improperly assessing stress limitations and bathroom-access needs. The disposition was designated nonprecedential.
Topics
Practice areas
Questions Presented
- Whether the ALJ provided legally sufficient reasons supported by substantial evidence for rejecting the opinions of Wolfram's treating physicians.
- Whether the ALJ's step-five hypothetical to the vocational expert accurately incorporated Wolfram's residual functional capacity, including his stress limitations and bathroom-break and bathroom-availability needs.
- Whether the district court properly affirmed the Commissioner's denial of disability insurance benefits.
Holdings
- The ALJ erred by rejecting the treating physicians' opinions without providing specific and legitimate reasons supported by substantial evidence. The nonexamining physicians' opinions and the wife's testimony did not supply adequate justification for rejecting the treating physicians' conclusion that Wolfram could perform no work involving stress.
- The ALJ erred by constructing an incomplete and insufficiently restrictive hypothetical that failed to account for Wolfram's actual residual functional capacity, including the evidence that he could not perform stressful work and his need for bathroom breaks and bathroom availability.
Key quotations
“The ALJ must provide “clear and convincing” reasons for rejecting the uncontra-dicted opinion of a treating or examining physician, and even if contradicted by another doctor, the opinion can be rejected only for specific and legitimate reasons supported by substantial evidence.” (351 F. App'x at 241)
“A job with medium stress is not a job with high stress, but it is also not “non-stressful work.”” (351 F. App'x at 243)
“In sum, the ALJ erred at step two of the analysis by rejecting the opinion of treating physicians without providing specific, legitimate reasons for doing so, and erred at step five of the analysis by constructing an improper hypothetical question that did not take into account the claimant’s actual functional residual capacity.” (351 F. App'x at 243)
Factual background
Wolfram sought disability insurance benefits based on irritable bowel syndrome, diverticulosis, incontinence, and anxiety. His treating physicians concluded that he was totally and permanently disabled and could not perform work involving stress. The ALJ rejected those opinions, apparently relying on nonexamining physicians and testimony from Wolfram's wife, and formulated a vocational hypothetical that did not accurately account for Wolfram's stress limitations or bathroom needs.
Procedural history
An administrative law judge denied Wolfram's claim for disability insurance benefits. The district court entered summary judgment for the Commissioner and affirmed the denial. The Ninth Circuit reversed and remanded with instructions for the agency to redetermine Wolfram's eligibility for benefits.
Remand instructions
Remand to the agency for redetermination of Wolfram's eligibility for benefits, applying proper reasons for evaluating the treating physicians' opinions and incorporating Wolfram's actual functional limitations into any vocational hypothetical.