Amy L. Senstad v. Commissioner of Social Security

Senstad · United States District Court for the Eastern District of California · March 26, 2025 · No. 2:23-CV-2930-DAD-DMC

Summary

The document contains findings and recommendations in a Social Security disability action challenging the Commissioner’s final decision under 42 U.S.C. § 405(g). The magistrate judge recommends rejecting the plaintiff’s challenges to the evaluation of her subjective symptoms and the vocational expert’s testimony concerning the Dictionary of Occupational Titles. The recommendations would deny the plaintiff’s motion for summary judgment, grant the Commissioner’s cross-motion, and affirm the administrative decision.

Holdings

  1. The ALJ adequately supported the evaluation of Senstad's subjective statements and testimony because the record contained specific evidence of inconsistency, including her statements about performing extensive international work travel involving substantial walking and climbing, as well as objective findings, treatment history, medication use, activities, and medical opinions.
  2. The ALJ adequately resolved the asserted inconsistency between the vocational-expert testimony and the Dictionary of Occupational Titles by finding that Senstad could perform display-designer work as generally performed at the light or sedentary level, but not as she had actually performed it at the heavy level, and by accepting vocational-expert testimony concerning the set-designer position.
  3. The Commissioner's final decision should be affirmed because it applied proper legal standards and was supported by substantial evidence.

Questions Presented

  1. Whether the ALJ provided legally sufficient reasons for evaluating Senstad's subjective statements and testimony concerning the intensity, persistence, and limiting effects of her symptoms.
  2. Whether the ALJ improperly relied on objective medical evidence, daily activities, treatment history, and international work travel in evaluating Senstad's subjective statements.
  3. Whether the ALJ adequately addressed any conflict between vocational-expert testimony and the Dictionary of Occupational Titles concerning Senstad's ability to perform her past relevant work as a display designer and set designer.
  4. Whether the Commissioner's final decision was supported by substantial evidence and applied proper legal standards.

Disposition

other

Cases Cited (28)

  • Tackett v. Apfel, 180 F.3d 1094, 1097, 1101 (9th Cir. 1999)(followed)
  • Saelee v. Chater, 94 F.3d 520, 521-22 (9th Cir. 1996)(followed)
  • Richardson v. Perales, 402 U.S. 389, 402 (1971)(followed)
  • Howard v. Heckler, 782 F.2d 1484, 1487 (9th Cir. 1986)(followed)
  • Jones v. Heckler, 760 F.2d 993, 995 (9th Cir. 1985)(followed)
  • Hammock v. Bowen, 879 F.2d 498, 501 (9th Cir. 1989)(followed)
  • Sprague v. Bowen, 812 F.2d 1226, 1229-30 (9th Cir. 1987)(followed)
  • Thomas v. Barnhart, 278 F.3d 947, 954, 958-59 (9th Cir. 2002)(followed)
  • Burkhart v. Bowen, 856 F.2d 1335, 1338, 1340 (9th Cir. 1988)(followed)
  • Quang Van Han v. Bower, 882 F.2d 1453, 1456 (9th Cir. 1989)(followed)

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