Smartt v. Kijakazi

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Disability Law
  • Date Filed: 11-17-2022
  • Case #: 21-16009
  • Judge(s)/Court Below: VanDyke, J. for the Court; Gilman, J.; Callahan, J.
  • Full Text Opinion

"When faced with contradicted medical testimony, an ALJ must provide specific and legitimate reasons supported by substantial evidence in the record for rejecting a treating physician's opinion". Lester v. Chater, 81 F.3d 821, 830 (9th Cir. 1995).

Months after suffering a head injury from a fall, Petitioner sought out a doctor to sign off on their disability claim paperwork so Petitioner could apply for Social Security disability benefits. After finding a doctor who would sign off on the paperwork, Petitioner applied for benefits but the ALJ denied on the grounds that Petitioner did not have a disability. The district court affirmed ALJ’s determination and Petitioner appealed to the Ninth Circuit Court of Appeals, arguing ALJ erred in its determination of denying benefits. The Ninth Circuit held that ALJ did not err in determining that the Petitioner did not qualify for Social Security disability benefits because the ALJ’s decision was supported by substantial evidence. The Court reasoned that ALJ properly discounted the original report by Petitioner’s doctor which described Petitioner as having extreme limitations because it was contrary to the consultative examiner’s opinion. Additionally, the medical records that show Petitioner maintained normal range of motion. The Court also reasoned that Petitioner’s self-reported limitations and descriptions of pain were inconsistent to Petitioner’s daily activities. AFFIRMED.

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