Jennie C. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of California denied Plaintiff Jennie C.’s motion for summary judgment and granted the Commissioner of Social Security’s cross-motion. The court upheld the Administrative Law Judge’s determination that Plaintiff was not disabled from January 31, 2015 through January 23, 2019, while finding that she became disabled on January 24, 2019. The court concluded that the ALJ properly evaluated the treating physician’s opinions and Plaintiff’s subjective symptom testimony.

Holdings

1. The ALJ did not err in assigning little weight to Dr. Posada's opinions because the opinions lacked adequate support and were inconsistent with the medical evidence and record as a whole.
2. The ALJ did not err in discounting Plaintiff's subjective testimony because the ALJ provided specific, clear, and convincing reasons supported by substantial evidence, including inconsistencies between the testimony and medical evidence, inconsistent symptom reports, and poor effort during examinations.
3. The ALJ did not err by failing to include in the vocational-expert hypotheticals limitations drawn from Dr. Posada's opinions and Plaintiff's testimony because the ALJ properly discounted both sources.

Questions Presented

1. Whether the ALJ provided legally sufficient reasons supported by substantial evidence for assigning little weight to treating physician Dr. Posada's medical opinions.
2. Whether the ALJ provided specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom testimony.
3. Whether the ALJ erred by posing incomplete hypothetical questions to the vocational expert.

Disposition

affirmed