Michelle Garcia v. Commissioner, Social Security

MEMORANDUM

1. Michelle Garcia’s objections to the ALJ’s treatment of conflicting medical testimony do not provide a basis for reversal. The ALJ rejected the opinion of Garcia’s treating psychologist, Dr. William Taetzsch — the only medical expert to conclude Garcia was entirely unfit for work— as an outlier “so extreme as to appear implausible.” Ordinarily, a treating physician’s opinion outweighs a non-treating physician’s opinion. See Lester v. Chater, 81 F.3d 821, 830-31 (9th Cir.1996). But in this case, the ALJ rejected Dr. Taetzsch’s opinion in favor of the examining physicians’ opinions for “specific and legitimate” reasons supported by substantial evidence. Id. at 830 . The ALJ fairly decided that Dr. Taetzsch’s conclusory determinations that Garcia had, for instance, poor or no ability to deal with work stresses and to perform work activities, are unsupported by Dr. Taetzsch’s own notes, which almost exclusively concern Garcia’s relationship with her son and her physical health and provide almost no analysis. The ALJ reasonably gave controlling weight to the three other independent medical opinions, because they were consonant with Garcia’s broader medical history.…