Lambert v. Saul, No. 19-17102 (9th Cir. 2020)
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The Ninth Circuit vacated the district court's judgment affirming the denial of claimant's application for social security disability benefits. In Bellamy v. Secretary of Health and Human Services, 755 F.2d 1380 (9th Cir. 1985), the panel held that a claimant's prior disability determination entitled claimant to a presumption of continuing disability. The SSA interpreted then-recent amendments to the Social Security Act as foreclosing any presumption of continuing disability.
Deferring to the SSA's intervening interpretation of the Social Security Act, which is a reasonable one, the panel held that there is no presumption of continuing disability under the Act. Consequently, the ALJ did not err in evaluating, without any such presumption, the SSA's determination that claimant is no longer disabled. However, the ALJ did err in failing to articulate sufficient reasons for refusing to credit plaintiff's testimony about the severity of her medical condition. The panel remanded for further proceedings.
Court Description: Social Security The panel vacated the district court’s judgment affirming the denial of claimant’s application for disability benefits under the Social Security Act, and remanded with instructions to remand to the administrative law judge (“ALJ”) for further proceedings. A Social Security ALJ found claimant disabled beginning June 1, 2005. The Commissioner of the Social Security Administration (“SSA”) conducted periodic continuing disability reviews, and determined that claimant’s disability ended January 1, 2015. After this court issued Bellamy v. Secretary of Health and Human Services, 755 F.2d 1380 (9th Cir. 1985) (holding that a claimant’s prior disability determination entitled claimant to a presumption of continuing disability), the SSA interpreted then-recent amendments to the Social Security Act as foreclosing any presumption of continuing disability. The panel held that it must defer to the SSA’s intervening interpretation of the statute, which was a reasonable one. The panel held, therefore, that there was no presumption of continuing disability under the Social Security Act. The panel concluded that the ALJ did not err in evaluating, without any such presumption, the SSA’s determination that the claimant was no longer disabled. LAMBERT V. SAUL 3 The panel held that the ALJ erred in failing to articulate sufficient reasons for refusing to credit claimant’s testimony about the severity of her medical condition. Here, the ALJ did not identify the specific testimony that he discredited, and did not explain the evidence undermining it. The panel held that the ALJ was required to do more than was done here, which consisted of offering non-specific conclusions that claimant’s testimony was inconsistent with her medical treatment. Finally, the panel held that the ALJ’s error was not harmless.
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