Unreported / Non-Citable
Background
Miranda Perez protectively filed applications for disability insurance benefits and supplemental security income on April 8, 2022, alleging disability beginning March 1, 2020, due to diabetes mellitus, long COVID, obesity, grey platelet syndrome/anemia, depression, and anxiety. After initial and reconsideration denials, an ALJ held a video hearing on December 9, 2024, and found Perez not disabled. The ALJ determined at step two that Perez had the listed severe impairments; at step three, that they did not meet or equal a listing; and assessed an RFC for a full range of exertional work with nonexertional limitations: never climb ladders/ropes/scaffolds, avoid unprotected heights and dangerous machinery, perform only simple routine tasks, maintain only occasional social contact, and avoid daily/hourly production quotas. At step five, the ALJ identified jobs such as industrial cleaner, kitchen helper, and hospital cleaner existing in significant numbers. The Appeals Council denied review, making the ALJ's decision final. Perez sought judicial review in the Eastern District of California, and the matter was referred to Magistrate Judge Helena M. Barch-Kuchta under 28 U.S.C. § 636(b)(1)(B).
Perez raised two issues: whether the ALJ properly considered the medical opinion of Dr. Houshang Aminian, who assessed a marked limitation in responding appropriately to usual work situations and changes in routine; and whether the RFC was supported by substantial evidence given the ALJ's alleged failure to include limitations from fatigue and other severe impairments. The magistrate judge reviewed the administrative record, the parties' briefs, and applicable Ninth Circuit precedent governing substantial evidence review and the evaluation of medical opinions under 20 C.F.R. §§ 404.1520c, 416.920c.
The Court’s Holding
The magistrate judge recommends denying Perez's motion for summary judgment, granting the Commissioner's cross-motion, and affirming the Commissioner's decision. On the first issue, the court found substantial evidence supported the ALJ's decision to give Dr. Aminian's opinion general persuasiveness but reject the marked limitation as too restrictive and inconsistent with Perez's reported daily activities — including shopping, driving, using a computer, managing finances, and using public transportation per an August 2022 psychological evaluation — and with longitudinal treatment records showing repeated denials of depression and anxiety and normal mental status examinations. The ALJ adequately articulated the supportability and consistency analysis required by 20 C.F.R. § 416.920c(c)(1)-(2) and Woods v. Kijakazi, 32 F.4th 785 (9th Cir. 2022).
On the RFC issue, the court found the ALJ provided a detailed review of the medical evidence, properly evaluated opinions from state agency consultant Dr. Julie Chu and consultative examiner Dr. Steven Stoltz (both found persuasive), and accounted for fatigue from diabetes, blood disorders, long COVID, and obesity by including the postural and environmental restrictions in the RFC. The court held that Perez failed to identify specific functional limitations from fatigue not already captured, and that the mere diagnosis of an impairment does not compel additional RFC restrictions. The ALJ's RFC was consistent with the assessed limitations and supported by substantial evidence. No harmful legal error was found.
Key Takeaways
- The ALJ's rejection of a medical opinion's marked mental limitation was upheld where the ALJ cited the claimant's reported daily activities and longitudinal treatment records showing normal mental status exams and repeated denials of mental health symptoms, satisfying the supportability and consistency factors under the revised medical opinion regulations.
- An RFC that includes nonexertional limitations (no ladders/ropes/scaffolds, avoid heights/dangerous machinery, simple routine tasks only, occasional social contact, no production quotas) can adequately account for fatigue and other symptoms even if the claimant argues for more restrictive limitations, provided the ALJ explains the translation of medical findings into work restrictions.
- A claimant's failure to challenge the ALJ's assessment of other medical opinions (here, state agency and consultative examiners) that support the RFC can be fatal to an argument that the RFC omits limitations from severe impairments.
- Substantial evidence review requires the court to uphold the ALJ's conclusion when the evidence is susceptible to more than one rational interpretation; the court may not substitute its judgment for the Commissioner's.
- The magistrate judge's findings and recommendations are subject to a 14-day objection period before the assigned district judge; failure to object may waive certain appellate rights under Ninth Circuit precedent.
Why It Matters
This decision illustrates the application of the SSA's revised medical opinion regulations (20 C.F.R. §§ 404.1520c, 416.920c) in the Ninth Circuit, emphasizing that an ALJ must articulate consideration of supportability and consistency for each medical opinion but may discount a source's opinion when it conflicts with the claimant's reported functioning and the broader record. The ruling also reinforces that RFC assessments need not mirror every cited symptom verbatim but must reflect a logical translation of credible, supported limitations into work-related restrictions.
The recommendation, subject to district judge adoption, affirms the Commissioner's denial of benefits in a post-COVID, multi-impairment case where the ALJ found the claimant capable of unskilled work with specific nonexertional safeguards.