Jerrie Archer v. Carolyn W. Colvin

MEMORANDUM

Jerrie A. Archer appeals the district court’s judgment 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. We have jurisdiction under 28 U.S.C. § 1291 . We review de novo, Molina v. Astrue, 674 F.3d 1104, 1110 (9th Cir.2012), and affirm.

1. The administrative law judge (“ALJ”) provided specific, clear, and convincing reasons for rejecting Archer’s subjective complaints, including her daily activities, her failure to seek or comply with counseling treatment, failure to take prescribed medication, and lack of supporting medical evidence. See Smolen v. Chater, 80 F.3d 1273, 1284 (9th Cir.1996) (discussing factors considered in evaluating credibility).

2. In rejecting the testimony of Archer’s daughter, Sara Ball, the ALJ provided reasons “germane to the witness” for doing so, by questioning Ball’s ability to adequately observe Archer, and by noting that Ball’s testimony was inconsistent with the medical evidence. See Molina, 674 F.3d at 1114 (reciting standard); Bayliss v. Barnhart, 427 F.3d 1211, 1218 (9th Cir.2005) (citing…