Vertner v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviews the Commissioner of Social Security’s denial of Angell Vertner’s application for supplemental security income. The court concludes that the ALJ failed to provide clear, convincing, and specific reasons supported by substantial evidence for discounting Vertner’s symptom testimony and remands the case for further administrative proceedings.

Holdings

1. The ALJ failed to provide clear, convincing, and specific reasons supported by substantial evidence for rejecting Vertner's symptom testimony.
2. The ALJ must reconsider the effects of Vertner's headaches and hearing loss because the findings that those conditions were well-managed or successfully addressed were not supported by substantial evidence.
3. Remand for further administrative proceedings, rather than an immediate award of benefits, was appropriate.

Questions Presented

1. Whether the ALJ provided legally sufficient, clear, convincing, and specific reasons supported by substantial evidence for discounting Vertner's subjective symptom testimony.
2. Whether the ALJ properly evaluated the severity and limiting effects of Vertner's migraine headaches and sensorineural hearing loss.
3. Whether the ALJ adequately considered the exacerbating impact of Vertner's obesity.
4. Whether the appropriate remedy was remand for further administrative proceedings or an immediate award of benefits.

Disposition

reversed_and_remanded