Smith v. Kijakazi, No. 20-35487 (9th Cir. 2021)
Annotate this CaseThe Ninth Circuit reversed the district court's decision affirming the ALJ's 2019 decision denying claimant's application for social security disability benefits. The panel concluded that, although the ALJ's conclusion that claimant was not disabled at the time of the hearing was supported by substantial evidence, the ALJ did not adequately consider claimant's symptoms over time. The panel explained that the ALJ's failure to consider these changes over time impacted both her assessment of claimant's credibility and her analysis of the medical opinions. Therefore, on remand, the ALJ shall consider whether claimant was disabled and thus entitled to benefits, for some qualifying, earlier portion of his alleged disability period.
Court Description: Social Security. The panel reversed the district court’s affirmance of a 2019 decision of an administrative law judge (“ALJ”) denying a claimant’s application for Social Security disability benefits. The panel held that the ALJ’s conclusion that claimant was not disabled at the time of the hearing was supported by substantial evidence. The panel nonetheless reversed and remanded to the agency for further factfinding because the agency did not adequately consider how claimant’s symptoms changed over time. The ALJ’s failure to consider these changes over time impacted both her assessment of claimant’s credibility and her analysis of the medical opinions. Specifically, the panel held that although the ALJ properly determined that claimant’s testimony was not credible regarding his capacity in the later period of his disability claim, the ALJ erred in rejecting claimant’s testimony wholesale without explaining how her rationale for finding the late period testimony not credible applied to the early period testimony. In addition, the ALJ erred by failing to consider whether the opinions of Drs. Wheeler and Krueger were reliable evidence of claimant’s functioning in the earlier time period and instead seeking only a single medical opinion of claimant’s general capacity over the entire period. The panel concluded that these errors were harmful. The panel instructed the ALJ on remand to SMITH V. KIJAKAZI 3 consider whether claimant was disabled, and therefore entitled to benefits, for some qualifying, earlier portion of his alleged disability period.
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