Unreported / Non-Citable
Background
Angela Castillo applied for disability insurance benefits, alleging disability due to multiple sclerosis (MS) and vitamin B-12 deficiency. An Administrative Law Judge (ALJ) denied benefits after finding Castillo retained the residual functional capacity (RFC) to perform sedentary work.
The ALJ discounted medical opinions from a September 2022 neurological consultative examination and a June 2023 examining physician, both of which opined Castillo could perform less than the full range of sedentary work. The ALJ also rejected Castillo’s subjective symptom testimony regarding the severity of her limitations. The district court affirmed the ALJ’s decision, and Castillo timely appealed to the Ninth Circuit.
The Court’s Holding
The Ninth Circuit affirmed the district court’s judgment. The panel held that substantial evidence supported the ALJ’s decision to discount the two medical opinions because they were unsupported by the physicians’ own examination findings and inconsistent with the broader record showing largely normal gait, strength, sensation, and reflexes.
The ALJ properly accounted for Castillo’s vitamin B-12 deficiency in the RFC, noting her noncompliance with B-12 injections that had previously resolved her symptoms and the absence of medical opinions or objective evidence linking the deficiency to work-related mental restrictions. The ALJ provided specific, clear, and convincing reasons to reject Castillo’s subjective testimony by citing conflicts with objective medical evidence and inconsistencies with her reports to treating providers. Because the RFC was supported by substantial evidence, the ALJ’s hypothetical to the vocational expert was not incomplete.
Key Takeaways
- Under 20 C.F.R. § 416.920c, supportability and consistency are the most important factors in weighing medical opinions; opinions unsupported by a physician’s own clinical findings or inconsistent with the record may be discounted.
- An ALJ may reject a medical opinion presented in a check-box format with little to no explanatory support.
- Noncompliance with prescribed treatment that previously resolved symptoms (here, B-12 injections) can undermine a claim of disability severity.
- Specific, clear, and convincing reasons for rejecting subjective symptom testimony include conflicts with objective medical evidence and discrepancies between hearing testimony and reports to treating providers.
- A challenge to a vocational expert hypothetical fails if it is derivative of an unsuccessful challenge to the underlying RFC assessment.
Why It Matters
This memorandum disposition applies the post-2017 medical opinion regulations (20 C.F.R. § 416.920c) to affirm an ALJ’s discounting of consultative and examining physician opinions that relied on subjective complaints and check-box forms rather than objective clinical findings. It reinforces that normal or near-normal objective neurological findings—even in a claimant with relapsing-remitting MS—can constitute substantial evidence contradicting opinions of severe functional limitation. The decision also illustrates the interplay between treatment noncompliance and RFC assessment, and the requirement that ALJs ‘show their work’ when rejecting subjective testimony by identifying specific record contradictions. The memorandum applied deferential substantial-evidence review to the administrative record. It did not hold that check-box medical opinions are categorically invalid or that subjective symptom testimony may be rejected merely because objective evidence is limited.
Rather, it approved the ALJ’s stated reasons in this record: the treating opinion lacked supporting explanation and conflicted with other evidence, while Castillo’s reported limitations conflicted with examination findings and some of her own reports to providers. Because the residual functional capacity finding survived review, the derivative challenge to the vocational-expert hypothetical also failed. The panel affirmed the denial of benefits and ordered no further administrative proceedings. The ruling is case-specific and should be read with its procedural posture and, where applicable, its nonprecedential status in mind. The result is narrowly framed. Practitioners should distinguish the court’s actual disposition from issues it mentioned but expressly left unresolved.