Wendy Jerome v. Carolyn W. Colvin

MEMORANDUM

Wendy Jerome appeals the district court’s grant of summary judgment in favor of the Commissioner’s denial of disability benefits. We have jurisdiction pursuant to 28 U.S.C. § 1291 and review the administrative decision for substantial evidence. Molina v. Astrue, 674 F.3d 1104, 1110-11 (9th Cir.2012). We affirm.

Jerome asserts that the ALJ: (1) erred when he failed to deem her right arm paresthesia, her cervical stenosis, and her urinary stress incontinence as “severe” impairments; (2) erred when he rejected her treating physician’s opinion that she could only occasionally use her right hand and had severe limitations on her ability to stand and walk; (3) erred in his determination as to her credibility; and (4) erred in his rejection of the conclusions reached by the vocational expert when she was asked to compare Jerome’s limitations to a hypothetical situation posed to her.

First, even if we were to hold that the ALJ committed legal error by finding that Jerome’s right-arm paresthesia and cervical stenosis were not severe, such error would be harmless. The ALJ found that Jerome’s HIV and spinal fracture were severe impairments, and then considered evidence of all…