Jennifer Flores v. Leland Dudek, Acting Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviewed the denial of Jennifer Flores’s applications for disability insurance benefits and Supplemental Security Income. The court held that the ALJ failed to provide sufficiently specific, clear, and convincing reasons for discounting Flores’s subjective symptom statements. The court vacated the decision and remanded the case for further proceedings.

Holdings

1. Any error in the ALJ's application of SSR 18-3p was harmless because the ALJ did not base the nondisability determination on Flores's failure to follow prescribed treatment; the ALJ found at step five that she could perform work existing in significant numbers in the national economy.
2. The ALJ erred by discounting Flores's subjective statements based on generalized assertions that they were inconsistent with objective clinical findings, the treatment record, and treatment notes. When a claimant presents objective evidence of an impairment capable of producing the alleged symptoms and there is no evidence of malingering, the ALJ must provide specific, clear, and convincing reasons for rejecting testimony about symptom severity.
3. The proper remedy was to vacate the Commissioner's decision and remand for further administrative proceedings rather than order immediate payment of benefits.

Questions Presented

1. Whether any error in the ALJ's application of Social Security Ruling 18-3p concerning failure to follow prescribed treatment required reversal.
2. Whether the ALJ provided specific, clear, and convincing reasons supported by substantial evidence for discounting Flores's subjective statements about the intensity, persistence, and limiting effects of her mental symptoms.
3. Whether the appropriate remedy was remand for further proceedings or an immediate award of benefits.

Disposition

vacated