Coleman v. Saul, No. 19-35700 (9th Cir. 2020)
Annotate this CaseThe Ninth Circuit affirmed the denial of social security disability benefits to claimant under Title II of the Social Security Act. The panel held that the ALJ did not err in discounting claimant's testimony where substantial evidence supported the ALJ's finding that claimant had engaged in drug-seeking behavior; the ALJ did not err in weighing the medical-opinion evidence; and the ALJ did not err in excluding pain disorder as a severe impairment.
Court Description: Social Security The panel affirmed the district court’s decision affirming the Commissioner of Social Security’s denial of a claimant’s application for disability insurance benefits under Title II of the Social Security Act. The panel held that the administrative law judge (“ALJ”) did not err in discounting the claimant’s testimony based on her finding that claimant had engaged in drug-seeking behavior. The panel held that substantial evidence supported this finding. The panel further held that the medical record reflected conduct by claimant inconsistent with his subjective complaints. The panel concluded that the ALJ provided clear and convincing reasons to discount claimant’s testimony. The panel held that the ALJ did not err in weighing the medical opinion evidence because she provided legally sufficient reasons to weight the medical testimony in the manner in which she did. Specifically, the ALJ did not err in concluding that the opinions assessing severe limitations were unsupported by the record, thus furnishing a specific and legitimate reason to discount the opinions of Dr. Foster and Dr. Jackson and a germane reason to disregard the opinion of Nurse Practitioner Schwarzkopf. In addition, the ALJ did not err in disregarding or discounting the medical opinions that relied on claimant’s self-reports of pain. COLEMAN V. SAUL 3 Finally, the panel held that the ALJ did not err in excluding pain disorder as a severe impairment at Step Two of the five-step disability determination framework set forth in 20 C.F.R. § 404.1520(a) because substantial evidence supported that determination.
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