(SS) Vang v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedMay 16, 2025
Docket1:24-cv-01293
StatusUnknown

This text of (SS) Vang v. Commissioner of Social Security ((SS) Vang v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(SS) Vang v. Commissioner of Social Security, (E.D. Cal. 2025).

Opinion

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4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8 9 PA VANG, Case No. 1:24-cv-01293-EPG 10 Plaintiff, FINAL JUDGMENT AND ORDER 11 REGARDING PLAINTIFF’S SOCIAL v. SECURITY COMPLAINT 12 COMMISSIONER OF SOCIAL SECURITY, (ECF Nos. 1, 13) 13 Defendant. 14 15 This matter is before the Court on Plaintiff’s complaint for judicial review of an 16 unfavorable decision by the Commissioner of the Social Security Administration regarding her 17 application for disability benefits. The parties have consented to entry of final judgment by the 18 United States Magistrate Judge under the provisions of 28 U.S.C. § 636(c) with any appeal to the 19 Court of Appeals for the Ninth Circuit. (ECF No. 9). 20 Plaintiff argues as follows: 21 1. The ALJ erred by rejecting Plaintiff’s testimony without giving specific, clear 22 and convincing reasons. 23 2. The ALJ erred by improperly evaluating the treating clinical psychologists’ medical source statements. 24 3. The ALJ erred in finding the prior psychological administrative medical 25 findings persuasive. 26 (ECF No. 13, pp. 1-2). 27 Having reviewed the record, administrative transcript, the parties’ briefs, and the 28 applicable law, the Court finds as follows. 2 A. Subjective Complaints 3 Plaintiff argues that the ALJ erred by discounting her testimony. (ECF No. 13, p. 13). 4 Defendant argues that the ALJ gave multiple sufficient reasons to discount her testimony. (ECF 5 No. 14, p. 16). 6 As this claim ultimately concerns the RFC, the Court begins by noting the following legal 7 standards. A claimant’s RFC is “the most [a claimant] can still do despite [her] limitations.” 20 8 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1); see also 20 C.F.R. Part 404, Subpart P, Appendix 2, 9 § 200.00(c) (defining an RFC as the “maximum degree to which the individual retains the 10 capacity for sustained performance of the physical-mental requirements of jobs”). “In 11 determining a claimant’s RFC, an ALJ must consider all relevant evidence in the record, 12 including, inter alia, medical records, lay evidence, and the effects of symptoms, including pain, 13 that are reasonably attributed to a medically determinable impairment.” Robbins v. Soc. Sec. 14 Admin., 466 F.3d 880, 883 (9th Cir. 2006) (internal quotation marks and citations omitted). In 15 reviewing findings of fact with respect to RFC assessments, this Court determines whether the 16 decision is supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence means 17 “more than a mere scintilla,” Richardson v. Perales, 402 U.S. 389, 402 (1971), but less than a 18 preponderance. Sorenson v. Weinberger, 514 F.2d 1112, 1119, n. 10 (9th Cir. 1975). It is “such 19 relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” 20 Richardson, 402 U.S. at 401 (internal citation omitted). 21 Here, the ALJ formulated the following RFC: 22 After careful consideration of the entire record, I find that the claimant has the residual functional capacity to perform a full range of work at all exertional levels 23 but with the following nonexertional limitations: she can perform work at a moderate noise level; she can perform low-stress jobs, defined as those having 24 only occasional decision making required and only occasional changes in the work 25 setting; she can understand and perform simple, routine tasks; and she can have occasional interaction with supervisors and coworkers, but no interaction with the 26 public. 27 (A.R. 15). 28 2 on her subjective complaints, but generally indicates that the RFC should have incorporated 3 further restrictions regarding her hearing loss, mental health symptoms, and memory problems. 4 (ECF No. 13, pp. 14-15). 5 As to a plaintiff’s subjective complaints, the Ninth Circuit has concluded as follows: 6 Once the claimant produces medical evidence of an underlying impairment, the Commissioner may not discredit the claimant’s testimony as to subjective 7 symptoms merely because they are unsupported by objective evidence. Bunnell v. Sullivan, 947 F.2d 341, 343 (9th Cir. 1991) (en banc); see also Cotton v. Bowen, 8 799 F.2d 1403, 1407 (9th Cir. 1986) (“it is improper as a matter of law to discredit 9 excess pain testimony solely on the ground that it is not fully corroborated by objective medical findings”). Unless there is affirmative evidence showing that the 10 claimant is malingering, the Commissioner’s reasons for rejecting the claimant’s 11 testimony must be “clear and convincing.” Swenson v. Sullivan, 876 F.2d 683, 687 (9th Cir. 1989). General findings are insufficient; rather, the ALJ must identify 12 what testimony is not credible and what evidence undermines the claimant’s complaints. 13 Lester v. Chater, 81 F.3d 821, 834 (9th Cir. 1995), as amended (Apr. 9, 1996). 14 However, “[t]he standard isn’t whether [the] court is convinced, but instead whether the 15 ALJ’s rationale is clear enough that it has the power to convince.” Smartt v. Kijakazi, 53 F.4th 16 489, 499 (9th Cir. 2022). An ALJ’s reasoning as to subjective testimony “must be supported by 17 substantial evidence in the record as a whole.” Johnson v. Shalala, 60 F.3d 1428, 1433 (9th Cir. 18 1995); see Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155, 1161 (9th Cir. 2008) 19 (“Accordingly, our next task is to determine whether the ALJ’s adverse credibility finding of 20 Carmickle’s testimony is supported by substantial evidence under the clear-and-convincing 21 standard.”). 22 Here, the ALJ concluded that Plaintiff’s “medically determinable impairments could 23 reasonably be expected to cause the alleged symptoms.” (A.R. 16). Accordingly, because there is 24 no affirmative evidence showing that Plaintiff was malingering, the Court looks to the ALJ’s 25 decision for clear and convincing reasons, supported by substantial evidence, for not giving full 26 weight to Plaintiff’s symptom testimony. 27 The ALJ summarized Plaintiff’s subjective complaints as follows: 28 children. She had a driver’s license. She last drove 2 years ago. Her relatives drove 2 her places. The claimant last worked as a material handler at Logic PD. She was laid off. The claimant testified that her ability to work was limited by her hearing 3 and forgetfulness. She treated with Dr. Popper for 2 years. She saw him once a week. Concerning her depression, she did not want to live because she could not 4 hear well. Her family reminded her of appointments and to take her medicine. She 5 could not cook or help around the house. The claimant asked what she did on an average day, and she responded that she did not do anything. She stayed in her 6 room by herself. 7 (A.R. 16).

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(SS) Vang v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-vang-v-commissioner-of-social-security-caed-2025.