Starkweather v. Bisignano – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the denial of Social Security disability benefits, ruling that any errors in the ALJ's evaluation of medical evidence were harmless and that the appellant forfeited other arguments.
Standard: Substantial evidence review
Vote: Unanimous decision by a three-judge panel.
Practical effect: The decision reinforces that minor procedural or factual errors by an Administrative Law Judge do not warrant reversal if substantial evidence independently supports the denial of benefits.

The United States Court of Appeals for the Ninth Circuit affirmed the denial of Social Security disability benefits to Jeana Eileen Starkweather. Although the court identified minor errors in the Administrative Law Judge's evaluation of medical evidence, it ruled those errors were harmless.

Background

Jeana Eileen Starkweather appealed a district court order that affirmed an Administrative Law Judge’s denial of her Social Security disability benefits application. The appeal challenged the ALJ’s discounting of a medical assessment and the evaluation of her testimony and residual functional capacity.

The court’s reasoning

The court reviewed the case de novo to determine if the agency’s decision was supported by substantial evidence or based on legal error. The court acknowledged the ALJ overlooked a 2016 medical visit and failed to consider Starkweather’s lack of insurance as a reason for sporadic treatment. However, the court found these errors harmless because other substantial evidence, including physical examination records and the doctor’s own treatment notes, supported the conclusion that the assessment was unpersuasive. The court also held that Starkweather forfeited arguments regarding her testimony and the hypothetical posed to the vocational expert by failing to raise them in the district court.

What it means going forward

The decision reinforces that minor procedural or factual errors by an Administrative Law Judge do not warrant reversal if substantial evidence independently supports the denial of benefits.