Sandra Bennett v. Carolyn Colvin

MEMORANDUM

Sandra Bennett appeals from the district court’s affirmance of the denial of Social Security disability benefits. We affirm.

The Administrative Law Judge (“ALJ”) gave “specific and legitimate reasons that are supported by substantial evidence,” Bayliss v. Barnhart, 427 F.3d 1211, 1216 (9th Cir.2005), for discounting the opinion of Bennett’s treating physician. Substantial evidence supports the ALJ’s finding that the treating physician’s opinion was inconsistent with the medical record and Bennett’s work history. Any errors' in the ALJ’s additional reasoning were harmless. See Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir.2012).

The ALJ properly gave specific, clear, and convincing reasons for disbelieving Bennett’s subjective complaints of pain. See id. at 1112 . Bennett’s work history and layoff date were sufficient reasons to support the ALJ’s adverse credibility determination. See Bray v. Comm’r of Soc., Sec. Admin., 554 F.3d 1219, 1227 (9th Cir.2009); Bruton v. Massanari, 268 F.3d 824, 828 (9th Cir.2001). Any error in the ALJ’s additional reasoning was harmless. See Bray, 554 F.3d at 1227 .

The ALJ properly gave a germane reason for discounting Bennett’s…