Ahearn v. Saul, No. 19-35774 (9th Cir. 2021)
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The Ninth Circuit affirmed the district court's judgment affirming the ALJ's denial of claimant's application for Supplemental Security Income (SSI) under the Social Security Act. The panel published this decision to draw attention to the government's incorrect description, in its briefs in this and in other recent SSI cases, of the standard of review.
In an SSI case, the panel reviews the decision of the ALJ for substantial evidence. If substantial evidence in the record supports the ALJ's decision, the panel must defer to the ALJ. In the absence of substantial evidence, however, the panel must set aside the ALJ's decision. The panel is not restricted to setting aside the ALJ's decision only when the evidence in the record compels a contrary conclusion. The panel rejected the government's application of I.N.S. v. Elias-Zacarias, 502 U.S. 478 (1992), which is an immigration case, and clarified that Elias-Zacarias does not describe the standard of review in an SSI case. In this case, considering the record as a whole, the panel held that the ALJ's disability determination was supported by substantial evidence.
Court Description: Social Security. The panel affirmed the district court’s judgment affirming the administrative law judge’s denial of claimant’s application for Supplemental Security Income (“SSI”) under the Social Security Act. The panel rejected the government’s description of the standard of review for Social Security cases. Citing I.N.S. v. Elias-Zacarias, 502 U.S. 478 (1992), an immigration case, the government asserted that a reviewing court could set aside an ALJ’s conclusion in an SSI case only if the record compelled a contrary conclusion. The panel held that Elias- Zacarias did not describe the standard of review in an SSI case. The panel held that in an SSI case, the court reviews the decision of the ALJ for substantial evidence. If substantial evidence in the record supports the ALJ’s decision, the court must defer to the ALJ. In the absence of substantial evidence, however, the court must set aside the ALJ’s decision. The court is not restricted to setting aside the ALJ’s decision only when the evidence in the record compelled a contrary conclusion. Considering the record as a whole, the panel held that the ALJ’s disability determination was supported by substantial evidence. AHEARN V. SAUL 3
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