HUDNALL V. DUDEK, No. 23-3727 (9th Cir. 2025)
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John Hudnall, a former financial advisor, applied for disability benefits under the Social Security Act, claiming he had been unable to work since May 1, 2015, due to major depressive disorder, anxiety, and insomnia. His application included a function report from his wife, Miyuki Sato, detailing his limitations in daily activities and self-care. Despite this, the Social Security Administration denied his application and request for reconsideration. Hudnall then sought a hearing before an Administrative Law Judge (ALJ), who also denied his claim, finding him not disabled based on medical evidence and Hudnall's self-reported activities, without explicitly addressing Sato's lay evidence.
Hudnall appealed to the United States District Court for the Northern District of California, which granted summary judgment in favor of the Social Security Administration. Hudnall then appealed to the United States Court of Appeals for the Ninth Circuit.
The Ninth Circuit reviewed the case and affirmed the district court's judgment. The court held that under the Social Security Administration's new regulations, effective March 27, 2017, ALJs are no longer required to provide germane reasons for discounting lay witness testimony. The court found that these regulations, which state that ALJs are not required to articulate how they considered evidence from nonmedical sources, are within the Commissioner of Social Security's broad authority and are not arbitrary and capricious. Consequently, the ALJ did not err in discounting Sato's evidence without explanation. The court resolved all other issues in a concurrently filed memorandum disposition.
Court Description: Social Security Disability Benefits. The panel affirmed the district court’s judgment affirming the denial of John Hudnall’s application for disability benefits, and held that under the Social Security Administration’s new regulations promulgated in 2017, Administrative Law Judges (“ALJs”) are no longer required to provide germane reasons when discounting the testimony of lay witnesses.
Prior to the 2017 regulations, this court’s precedent required ALJs to give germane reasons to each witness when discounting nonmedical lay testimony in Social Security proceedings. The 2017 regulations provide that ALJs are not required to articulate how they considered evidence from nonmedical sources.
The panel held that because the revised Social Security regulations covering nonmedical evidence fall within the Commissioner of Social Security’s broad authority to promulgate evidentiary rules and nothing indicates that they are “arbitrary and capricious,” they are the new governing law. The regulations are clearly irreconcilable with this court’s precedent requiring “germane reasons” to reject lay witness testimony. Because the regulations constitute an intervening higher authority, the germane reasons precedent no longer applies to claims filed on or after March 27, 2017, and in considering such claims, ALJs need not explain their reasons for discounting evidence from nonmedical sources.
With this new governing framework in mind, the panel held that the ALJ did not err in discounting without explanation evidence that Hudnall’s wife provided regarding his limitations.
The panel resolved all other issues in a concurrently filed memorandum disposition.
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