CROSS V. O'MALLEY, No. 23-35096 (9th Cir. 2024)
Annotate this CaseThe United States Court of Appeals for the Ninth Circuit affirmed the decision of the district court, which upheld the Commissioner of Social Security's denial of a claimant's application for supplemental security income. The claimant argued that the Social Security Administration's 2017 revised regulations for evaluating medical opinions were partially invalid because they did not provide a reasoned explanation for permitting an administrative law judge to avoid articulating how he or she accounts for the "examining relationship" or "specialization" factors under the Social Security Act or the Administrative Procedure Act (“APA”). The court found that the Commissioner's decision to promulgate the 2017 medical evidence regulations fell within his wide latitude to make rules and regulations, particularly those governing the nature and extent of the proofs and evidence to establish the right to benefits. The court also joined the Eleventh Circuit in holding that the regulations were valid under the APA, as the agency's response to public comment and reasoned explanation for the regulatory changes established that the regulations were not arbitrary or capricious.
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 supplemental security income under Title XVI of the Social Security Act.
Claimant argued that the Social Security Administration’s 2017 revised regulations for evaluating medical opinions were partially invalid because they did not provide a reasoned explanation for permitting an administrative law judge to avoid articulating how he or she accounts for the “examining relationship” or “specialization” factors under the Social Security Act or the Administrative Procedure Act (“APA”).
The panel held that the 2017 medical-evidence regulations were valid under the Social Security Act. The Commissioner’s decision to promulgate the 2017 medical-evidence regulations fell within his “wide latitude” to make rules and regulations, particularly those governing the nature and extent of the proofs and evidence to establish the right to benefits.
The panel joined the Eleventh Circuit in holding that the regulations were valid under the APA. The agency’s response to public comment and reasoned explanation for the regulatory changes established that the regulations were not arbitrary or capricious.
The panel addressed claimant’s other claims in an unpublished memorandum disposition filed concurrently with this opinion.
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