Harris v. Commissioner of Social Security Administration

MEMORANDUM

Anita Harris appeals the district court’s judgment affirming the Commissioner’s denial of disability insurance benefits (“DIB”) and supplemental security income (“SSI”), alleging several errors. She requests that we reverse and remand for an award of benefits. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

1. Substantial evidence supported the ALJ’s decision to discredit the opinions of Harris’s treating physicians. See Lester v. Chater, 81 F.3d 821, 830 (9th Cir.1995).

The ALJ did not err in crediting treating surgeon Dr. Soldevilla’s opinion only to the extent it was consistent with Harris’s residual functional capacity (“RFC”). The ALJ reasonably interpreted Dr. Soldevilla’s statement that Harris would have “difficulty” working in a full-time competitive work environment as equivocal. This interpretation comported with the ALJ’s ultimate determination that Harris could perform less than the full range of sedentary work.

2. Nor did the ALJ err in rejecting medical source statements from Harris’s treating physician, Dr. Mitchell. Inconsistencies in Dr. Mitchell’s opinions undermined his credibility. See Bayliss v. Barnhart, 427 F.3d 1211, 1216 (9th…