Unreported / Non-Citable
Background
Jeffrey W. Vaughn applied for Social Security disability insurance benefits and supplemental security income in November 2021, alleging disability beginning in November 2018. After denials at the initial and reconsideration levels and a July 2024 telephonic hearing with a vocational expert, an administrative law judge (ALJ) found him not disabled in September 2024. The Appeals Council denied review in July 2025, and Vaughn sought review in the Eastern District of California. The parties consented to a magistrate judge, and the case was decided on their briefs.
The ALJ found several severe physical impairments, plus adjustment disorder with mixed anxiety and depressive symptoms and major depressive disorder, but concluded none met a listing. The residual functional capacity (RFC) allowed light work with postural, overhead-reaching, environmental and hazard limits and one mental limit: understanding, remembering and carrying out simple instructions. Using the Medical-Vocational Rules as a framework, the ALJ found jobs existing in significant numbers that Vaughn could perform. On review, Vaughn argued that the ALJ mishandled the opinion of examining psychologist Kellie Sulier, Psy.D., and failed to carry a credited limitation into the RFC.
The Court’s Holding
The court rejected Vaughn's attack on how the ALJ weighed Dr. Sulier's opinion. The ALJ found it partly supported: anxious mood and impaired concentration supported a limit on persisting through a workday, but normal findings such as cooperation, good eye contact and intact, linear thought content did not support moderate limits in interacting with others or handling stress. The ALJ also found those limits inconsistent with limited mental health treatment and six PHQ-2 screening scores of 0 in 2023 and 2024. The court declined to adopt Vaughn's proposed rule that blending supportability and consistency requires reversal, noting that Woods v. Kijakazi treated imprecise terminology as a clarity problem where the ALJ's meaning is evident. It found no cherry-picking, because attention, concentration, memory and reported symptoms did not necessarily bear on social interaction or stress, and a single 2021 score of 20 did not show fluctuating symptoms against the consistent later zeros.
The court nonetheless reversed because the ALJ did not adequately discuss how the credited part of Dr. Sulier's opinion was translated into the RFC. The ALJ accepted that anxiety and impaired concentration supported a limit on persisting throughout a workday, yet the RFC contained only a restriction to simple instructions. The Commissioner argued that restriction was a permissible translation of an undefined mild-to-moderate limit, relying on Stubbs-Danielson v. Astrue. The court disagreed: there, the simple-tasks limit matched another medical opinion, whereas here no other medical testimony showed the restriction addressed the credited limitation, and the ALJ referred to later-submitted evidence without identifying it. It found the Commissioner's other authorities, including Thomas, Hoopai and Kitchen, inapposite or unpersuasive.
The Commissioner did not explain how the error could be harmless, and none was apparent, because an RFC that ignores a claimant's limitations is defective and a vocational hypothetical must include all supported limitations. The court reversed and remanded for further proceedings, directed entry of judgment for Vaughn, and closed the case. It did not award benefits, and it did not decide Vaughn's remaining arguments, which it found unpersuasive or unnecessary to reach.
Key Takeaways
- An ALJ who credits a medical opinion's limit on persisting through a workday must show how the RFC accounts for it; a bare restriction to simple instructions may not suffice.
- Stubbs-Danielson does not automatically validate a simple-work restriction when no other medical opinion in the record supports that translation.
- Normal mental status findings, limited treatment and repeated PHQ-2 scores of 0 can support discounting moderate social and stress limitations.
- Blending the terms supportability and consistency is not reversible error where the ALJ's meaning is clear from context, though ALJs are urged to use the terms precisely.
- The remedy is remand for further proceedings rather than an award of benefits, so the agency must revisit the mental RFC.
Why It Matters
This is a district court order by a magistrate judge, not a published opinion, and it carries no binding precedential weight beyond the parties; it applies existing Ninth Circuit authority, including Rounds, Stubbs-Danielson and Woods, to one record. Its practical lesson is that when an ALJ credits a mental limitation, the decision must make clear where that limitation appears in the RFC, particularly when the only supporting source is a single examining psychologist.
The court upheld the ALJ's partial rejection of social and stress limits, and the reversal rests solely on the RFC translation gap. What the agency will do on remand, including whether it adds a persistence limitation or explains why simple instructions suffice, and whether disability will ultimately be found, remains open.