Background
Crystal L. Olson appealed the district court’s order affirming the Commissioner of Social Security’s denial of her application for supplemental security income under Title XVI of the Social Security Act. The appeal was decided without oral argument by a panel of three circuit judges.
The court’s reasoning
The court reviewed the district court’s decision de novo to determine whether the administrative law judge’s decision was supported by substantial evidence and free of legal error. The panel found that the administrative law judge articulated specific and legitimate reasons for discounting medical opinions, noting inconsistencies with the claimant’s statements, self-reported activities, and objective medical evidence. The court also upheld the administrative law judge’s decision to discount the claimant’s symptom testimony, citing clear and convincing reasons that her testimony was inconsistent with the record, her conservative treatment, and her daily activities. Additionally, the court affirmed the rejection of lay witness testimony, as the reasons for rejecting the claimant’s testimony were necessarily germane to the friend’s statements which mirrored her subjective complaints.
What it means going forward
The decision reinforces the Ninth Circuit’s standard that administrative law judges may discount claimant testimony and medical opinions when supported by specific, clear, and convincing reasons found in the record.