Background
Felipe Nery Roman appealed the district court’s order affirming an administrative law judge’s denial of his applications for disability insurance benefits and supplemental security income under Titles Two and Sixteen of the Social Security Act.
The court’s reasoning
The panel reviewed the district court’s order de novo, disturbing the denial of benefits only if the decision contained legal error or was not supported by substantial evidence. The court found substantial evidence supported the ALJ’s finding that Dr. Benjamin Metelits’s medical opinion was unpersuasive because it was unsupported by the doctor’s own treatment notes and inconsistent with the evidence as a whole. The court also found the AL’s interpretation of Dr. Kari Coelho’s opinion was rational. The court held it lacked jurisdiction to review the Appeals Council’s denial of review because it is not the final decision of the Commissioner. Finally, the court found Roman forfeited his remaining claims, including those regarding physical functioning and ineffective assistance of counsel, by failing to raise them before the district court.
What it means going forward
The decision reinforces the Ninth Circuit’s standard for reviewing Social Security disability denials, emphasizing that medical opinions unsupported by objective findings or inconsistent with the record may be rejected, and that failure to raise issues in district court results in forfeiture on appeal.