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52 soc.sec.rep.ser. 827, unempl.ins.rep. (Cch) P 15688b, 97 Cal. Daily Op. Serv. 1874, 97 Daily Journal D.A.R. 3493 Joseph Sandgathe v. Shirley S. Chater, Commissioner of Social Security
Citation: 108 F.3d 978Docket: 94-35757
Court: Court of Appeals for the Ninth Circuit; March 12, 1997; Federal Appellate Court
Joseph Sandgathe appeals a district court judgment affirming the Commissioner of Social Security's denial of his disability insurance benefits under Title II of the Social Security Act. The Ninth Circuit has jurisdiction over the appeal and reviews the district court’s judgment de novo. The court affirms the Commissioner's decision if it is supported by substantial evidence and adheres to correct legal standards. Substantial evidence is defined as relevant evidence that a reasonable mind might accept as adequate to support a conclusion, and the court must consider the entire administrative record, weighing both supportive and detractive evidence. The ALJ determined Sandgathe was not disabled, stating he could perform available light and sedentary work. Sandgathe contends the ALJ (1) wrongly discredited his claims of chronic pain, (2) improperly favored a medical consultant's opinion over that of his treating physician, Dr. Hayes, and (3) used incorrect legal standards in the disability determination. However, the first argument was not raised before the district court, so it is not addressed in the appeal. Regarding the second argument, the ALJ was criticized for not fully adopting Dr. Hayes's testimony, which indicated Sandgathe was "markedly limited" in several mental functioning capacities. In contrast, Dr. Moser, a consultant for the Commissioner, rated Sandgathe's limitations as "moderately limited." The court acknowledges that while treating physicians' opinions are generally given more weight, an ALJ may reject their testimony if there are specific and legitimate reasons backed by substantial evidence. The opinions of consultative physicians can also constitute substantial evidence for the ALJ's conclusions. Dr. Moser testified that some limitations identified in Dr. Hayes’ report regarding Sandgathe were due to unspecified physical issues. Dr. Hayes' findings were based on Sandgathe's self-reported physical ailments, which the ALJ deemed exaggerated, leading to the conclusion that Dr. Hayes' report was unreliable. The ALJ found Dr. Moser's testimony more credible, supported by evidence suggesting that Sandgathe's psychological issues might have been volitional or influenced by physical impairments. Consequently, the ALJ's reliance on Dr. Moser was backed by substantial evidence. Sandgathe contended that Social Security Ruling (SSR) 85-15 should guide the determination of his disability status, claiming entitlement to benefits due to mental limitations. SSR 85-15 applies when a claimant has solely nonexertional impairments. However, Sandgathe's claims include exertional limitations, such as difficulties in sitting and lifting, which are defined as exertional activities under SSR 83-10. Therefore, SSR 85-15 is not applicable to his case. All other arguments presented by Sandgathe were dismissed, and the decision was affirmed without the need for oral argument.