Summary
The United States District Court for the District of Oregon reviewed the Commissioner of Social Security’s denial of Caron Cox’s application for Disability Insurance Benefits. The court rejected challenges concerning development of the record, step-two and step-three findings, evaluation of symptom testimony, and the step-five vocational analysis. The court affirmed the Commissioner’s decision.
Holdings
- The ALJ did not fail to develop the record or deny Plaintiff due process because the record contained medical evidence from the relevant period and Plaintiff did not show that the evidence was ambiguous or inadequate.
- The ALJ did not err in finding that Plaintiff's obstructive sleep apnea and bilateral-hand osteoarthritis were not severe impairments during the relevant period.
- The ALJ reasonably determined that Plaintiff's impairments did not meet or medically equal a listed impairment during the relevant period.
- The ALJ provided specific, clear, and convincing reasons supported by substantial evidence for finding that Plaintiff's symptom allegations were not fully consistent with the record.
- The ALJ's step-five finding was supported by substantial evidence because Plaintiff's challenge to the hypothetical depended on limitations that the ALJ reasonably rejected.
Questions Presented
- Whether the ALJ failed to develop the record or denied Plaintiff due process by failing to obtain additional pre-date-last-insured evidence or call a medical expert.
- Whether the ALJ harmfully erred at step two by finding that obstructive sleep apnea and bilateral-hand osteoarthritis were not severe impairments.
- Whether the ALJ adequately evaluated whether Plaintiff's impairments met or medically equaled a listed impairment at step three.
- Whether the ALJ provided legally sufficient reasons for discounting Plaintiff's symptom testimony.
- Whether the ALJ's step-five vocational finding was supported by a complete hypothetical and substantial evidence.
Disposition
affirmed
Cases Cited (24)
- Bass v. Soc. Sec. Admin., 872 F.2d 832, 833 (9th Cir. 1989)(followed)
- Tackett v. Apfel, 180 F.3d 1094, 1097-98 (9th Cir. 1999)(followed)
- Luther v. Berryhill, 891 F.3d 872, 875 (9th Cir. 2018)(followed)
- Matney v. Sullivan, 981 F.2d 1016, 1018 (9th Cir. 1992)(followed)
- Smolen v. Chater, 80 F.3d 1273, 1279 (9th Cir. 1996)(followed)
- Richardson v. Perales, 402 U.S. 389, 401 (1971)(followed)
- Martinez v. Heckler, 807 F.2d 771, 772 (9th Cir. 1986)(followed)
- Treichler v. Comm'r of Soc. Sec. Admin., 775 F.3d 1090, 1098 (9th Cir. 2014)(followed)
- Consolo v. Fed. Mar. Comm'n, 383 U.S. 607, 621 (1966)(followed)
- Stout v. Comm'r, Soc. Sec. Admin., 454 F.3d 1050, 1054 (9th Cir. 2006)(followed)
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Court Document
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