Garrison v. Colvin, No. 12-15103 (9th Cir. 2014)
Annotate this CasePlaintiff appealed the denial of Social Security benefits. The court concluded that the ALJ erred in rejecting medical opinions, that she misunderstood a state examiner's opinion of plaintiff's impairments, and that she failed to meet the requirement of offering specific, clear, and convincing reasons for discrediting plaintiff's symptom testimony. The court reversed the district court's decision to remand the case to the ALJ for further proceedings and, instead, remanded to the district court with instructions to remand to the ALJ for a calculation and award of appropriate benefits. Plaintiff unquestionably satisfies all three conditions of the credit-as-true rule and a careful review of the record disclosed no reason to seriously doubt that she is, in fact, disabled.
Court Description: Social Security. The panel reversed the district court’s order remanding the case to the Commissioner of Social Security Administration for further proceedings, and instead remanded with instructions to the administrative law judge to calculate and award Social Security disability benefits to the claimant. The panel held that the administrative law judge (“ALJ”) erred in assessing the medical opinion evidence. The panel also held that the ALJ erred by failing to offer specific, clear, and convincing reasons for discrediting the claimant’s symptom testimony concerning her physical and mental impairments. The panel outlined the three-part credit-as-true standard, each part of which must be satisfied in order for a court to remand to an ALJ with instructions to calculate and award benefits: (1) the record has been fully developed and further administrative proceedings would serve no useful purpose; (2) the ALJ has failed to provide legally sufficient reasons for rejecting evidence, whether claimant testimony or medical opinion; and (3) if the improperly discredited evidence were credited as true, the ALJ would be required to find the claimant disabled on remand. The panel held that the district court abused its discretion by remanding for further proceedings where the credit-as-true rule was satisfied and the record afforded no reason to believe that the claimant was not, in fact, disabled. The panel held that a remand for a calculation and award of benefits was required.
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