Christy Hughes v. Carolyn Colvin

MEMORANDUM

Christy Hughes appeals the district court’s, decision affirming the Commissioner of Social Security’s denial of her application for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. Hughes contends that the ALJ erred by failing to consider the Global Assessment of Functioning (“GAF”) score from her treating psychiatric nurse practitioner Susan Caverly, Ph.D., ARNP. We have jurisdiction pursuant to 28 U.S.C. § 1291 . We affirm.

The ALJ did not err in failing to address Dr. Caverly’s GAF score, because a GAF score is merely a rough estimate of an individual’s psychological, social, or occupational functioning used to reflect an individual’s need for treatment, but it does not have any direct correlative work-related or functional limitations. See Vargas v. Lambert, 159 F.3d 1161 , 1164 n. 2 (9th Cir. 1998).

We do not agree with Hughes that Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) supports her position because Garrison is factually distinguishable. The nurse practitioner in Garrison was the primary psychiatric care giver, who treated the claimant for over two years, producing numerous reports,…