Summary
The United States District Court for the Central District of California reviewed the Commissioner of Social Security’s denial of Carmen R. H.’s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge failed to provide specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff’s subjective symptom statements. The decision was reversed and the matter was remanded for further administrative proceedings.
Holdings
- The ALJ failed to provide specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom statements.
- Remand for further administrative proceedings was warranted because the ALJ's symptom evaluation was legally erroneous and unsupported by substantial evidence.
Questions Presented
- Whether the ALJ provided specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom statements.
- Whether the ALJ's reliance on Plaintiff's basic daily activities and generally normal mental-status examinations adequately supported the adverse symptom evaluation.
Disposition
reversed_and_remanded
Cases Cited (22)
- Aukland v. Massanari, 257 F.3d 1033, 1035 (9th Cir. 2001)(followed)
- Smolen v. Chater, 80 F.3d 1273, 1279, 1284 (9th Cir. 1996)(followed)
- Reddick v. Chater, 157 F.3d 715, 720-21 (9th Cir. 1998)(followed)
- Kitchen v. Kijakazi, 82 F.4th 732, 738 (9th Cir. 2023)(followed)
- Kaufmann v. Kijakazi, 32 F.4th 843, 851 (9th Cir. 2022)(followed)
- Trevizo v. Berryhill, 871 F.3d 664, 678 (9th Cir. 2017)(followed)
- Garrison v. Colvin, 759 F.3d 995, 1014-16 (9th Cir. 2014)(followed)
- Robbins v. Social Security Administration, 466 F.3d 880, 883 (9th Cir. 2006)(followed)
- Brown-Hunter v. Colvin, 806 F.3d 487, 489, 494 (9th Cir. 2015)(followed)
- Smith v. Kijakazi, 14 F.4th 1108, 1112-14 (9th Cir. 2021)(followed)
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Court Document
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