Summary
The Ninth Circuit affirmed the judgment upholding the Commissioner of Social Security’s denial of Roy Worth’s application for disability insurance benefits. The court held that substantial evidence supported the ALJ’s findings that Worth’s impairments did not equal the relevant listings and that he retained the residual functional capacity for light or sedentary work with accommodations.
Topics
Practice areas
Questions Presented
- Whether substantial evidence supported the administrative law judge's determination that Worth's impairments were not medically equivalent to Listings 1.04(A) or 1.02(A).
- Whether substantial evidence supported the administrative law judge's determination that Worth retained the residual functional capacity to perform full-time light or sedentary work with accommodations.
- Whether the administrative law judge gave specific and legitimate reasons for rejecting Dr. Galvas's controverted opinion that Worth could not work a full day.
Holdings
- The administrative law judge's step-three determination that Worth's impairments were not medically equivalent to the listed impairments was supported by substantial evidence.
- The administrative law judge's determination that Worth could perform full-time light or sedentary work with accommodations was supported by substantial evidence.
Key quotations
“The ALJ provided several “specific and legitimate reasons” for rejecting Dr. Galvas’s controverted opinion that Worth could not work a full day” (at 644)
Factual background
Worth claimed disability based on impairments affecting his ability to work and walk. The medical record showed neither nerve-root compression nor related sensory or reflex loss, and his walking limitations were not sufficiently extreme to prevent effective ambulation. The administrative law judge found that Worth retained the residual functional capacity for full-time light or sedentary work with accommodations and rejected Dr. Galvas's contrary opinion because it conflicted with other medical evidence, contained internal inconsistencies, was inconsistent with Worth's reported daily activities, and lacked supporting medical findings.
Procedural history
The Commissioner denied Worth's application for disability insurance benefits. The district court affirmed the Commissioner's final decision, and Worth appealed to the Ninth Circuit. The Ninth Circuit affirmed, holding that substantial evidence supported the administrative law judge's findings regarding medical equivalence and residual functional capacity.