Summary
This Ninth Circuit opinion addresses whether Administrative Law Judges must provide germane reasons when discounting lay witness testimony in Social Security disability proceedings. The court holds that the Social Security Administration’s 2017 regulatory amendments, which relieve ALJs of the duty to articulate how they considered nonmedical evidence, supersede prior circuit precedent requiring such explanations for claims filed on or after March 27, 2017. Applying this updated framework, the panel affirms the district court’s judgment denying the appellant’s disability benefits claim.
Topics
Practice areas
Questions Presented
- Whether the ALJ erred by failing to provide germane reasons for discounting lay testimony from the claimant’s spouse under the Social Security regulations as amended in 2017.
Holdings
- ALJs are not required to provide germane reasons when discounting evidence from nonmedical sources for claims filed on or after March 27, 2017.
Key quotations
“Under the Social Security Administration’s new regulations promulgated in 2017, Administrative Law Judges (“ALJs”) are no longer required to provide germane reasons when discounting the testimony of lay witnesses.” (at 668)
“Because the revised Social Security regulations covering nonmedical evidence fall within the Commissioner of Social Security’s broad authority to promulgate evidentiary rules and nothing indicates that they are “arbitrary and capricious,” they are the new governing law.” (at 668)
Factual background
John Hudnall, a former financial advisor, applied for Social Security disability benefits in March 2020. The ALJ considered medical evidence and a lay report from Hudnall’s wife describing his limitations, but did not provide germane reasons for discounting the spouse’s testimony. The ALJ concluded Hudnall was not disabled and denied benefits.
Procedural history
The district court granted summary judgment for the Social Security Administration affirming the ALJ’s denial of benefits. Hudnall appealed the decision.