Background
Max Ortiz applied for Supplemental Security Income benefits in two thousand and fifteen, alleging disability due to chronic pain, seizure disorders, and mental health conditions including bipolar disorder and anxiety. The Administrative Law Judge denied the application in two thousand and twenty-three after a prior remand, finding Ortiz capable of medium work and discounting various medical opinions and subjective testimony regarding his limitations.
The court’s reasoning
The panel held that the Administrative Law Judge failed to provide specific and legitimate reasons supported by substantial evidence for discounting the treating source Dr. Shute’s analysis of Ortiz’s pain, particularly where routine observations did not address the specific pain complaints. The panel further found error in rejecting multiple psychological opinions that indicated marked or severe limitations, and in discrediting Ortiz’s testimony regarding seizures, depression, low energy, and anxiety. Because the record was fully developed, the panel determined that benefits should be awarded.
What it means going forward
The decision requires the Administrative Law Judge to calculate and award benefits to the claimant, reinforcing the requirement for specific reasons when rejecting treating source opinions and subjective testimony in Social Security cases.