Background
Brian Cody appealed the district court’s decision affirming the Commissioner of Social Security’s denial of his application for disability insurance benefits and supplemental security income. Cody challenged the administrative law judge’s assessment of medical evidence, his credibility determination, and the consideration of non-medical evidence.
The court’s reasoning
The court reviewed the administrative law judge’s decision de novo. It found that the administrative law judge provided clear and convincing reasons for discounting the opinions of treating and examining physicians, as those opinions were inconsistent with clinical findings and the record. The court also held that the administrative law judge provided specific, clear, and convincing reasons for discounting Cody’s symptom-related testimony, citing his minimal treatment history and daily activities inconsistent with his alleged limitations. The court further noted that the administrative law judge properly considered notes from a Social Security Administration interviewer and a social worker, and that any error in their consideration would be harmless.
What it means going forward
The decision reinforces the Ninth Circuit’s standard of review for Social Security disability claims, emphasizing that administrative law judges may discount medical opinions and claimant testimony when supported by substantial evidence in the record.
Podcast (federal-narrative-summaries): Play in new window | Download