LESLIE WOODS V. KILOLO KIJAKAZI, No. 21-35458 (9th Cir. 2022)
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Plaintiff sought benefits under the Social Security Act based on various physical and mental impairments. An administrative law judge (“ALJ”) found that she was not disabled and denied her claim. The district court affirmed.
The Ninth Circuit affirmed the district court’s decision affirming the Commissioner of Social Security’s denial of claimant’s application for benefits under the Social Security Act based on various physical and mental impairments.
The court decided that recent changes to the Social Security Administration’s regulations displaced case law requiring an administrative law judge (“ALJ”) to provide “specific and legitimate” reasons for rejecting an examining doctor’s opinion. The “relationship factors”, such as length and purpose of the treatment relationship, frequency of visits, and extent of examinations the medical source has performed are still relevant. However, the ALJ no longer needs to make specific findings regarding those factors. Under the new regulations, an ALJ cannot reject an examining or treating doctor’s opinion without providing an explanation supported by substantial evidence.
In this case, the ALJ acknowledged the doctor’s opinion that the claimant had marked and extreme limitations in various cognitive areas; but the ALJ found this opinion unpersuasive because it was inconsistent with the overall notes in the record. The court held that substantial evidence supported the ALJ’s finding.
Court Description: Social Security The panel affirmed the district court’s decision affirming the Commissioner of Social Security’s denial of claimant’s application for benefits under the Social Security Act based on various physical and mental impairments. As a threshold matter, the panel held that recent changes to the Social Security Administration’s regulations displaced longstanding case law requiring an administrative law judge (“ALJ”) to provide “specific and legitimate” reasons for rejecting an examining doctor’s opinion. For claims filed on or after March 27, 2017, that are subject to the new regulations, the former hierarchy of medical opinions – in which the court assigned presumptive weight based on the extent of the doctor’s relationship with the claimant – no longer applies. While the panel agreed with the government that the “specific and legitimate” standard was clearly irreconcilable with the 2017 regulations, the panel held that the extent of the claimant’s relationship with the medical provider – the “relationship factors” – remained relevant under the new regulations. An ALJ can still consider the length and purpose of the treatment relationship, the frequency of examinations, the kinds and extent of examinations that the medical source has performed or ordered from specialists, and whether the medical source has examined the claimant or merely reviewed the claimant’s records. However, the ALJ no longer needs to make specific findings regarding those relationship factors. Even under the WOODS V. KIJAKAZI 3 new regulations, an ALJ cannot reject an examining or treating doctor’s opinion as unsupported or inconsistent without providing an explanation supported by substantial evidence. Here, the ALJ acknowledged Dr. Causeya’s opinion that the claimant had marked and extreme limitations in various cognitive areas, including memory and concentration; but the ALJ found this opinion unpersuasive because it was inconsistent with the overall treating notes and mental status exams in the record. The panel held that substantial evidence supported the ALJ’s inconsistency finding. The panel rejected claimant’s contention that the ALJ failed to consider all her physical and mental limitations that are supported by the record. Because substantial evidence supported the ALJ’s decision here, the panel affirmed.
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