Bronson

MEMORANDUM

Plaintiff-Appellant Danette Bronson appeals the district court’s summary judgment in favor of the Commissioner of the Social Security Administration (“Commissioner”). Bronson argues that the Administrative Law Judge (“ALJ”) engaged in abusive conduct that exhibited improper bias against her. The magistrate judge acknowledged that “[throughout the course of the hearing, the ALJ repeatedly insulted and belittled plaintiffs counsel with sarcastic and degrading remarks” and that the “ALJ’s actions appear to have been unnecessary.”

Generally, we presume that an ALJ is unbiased. Rollins v. Massanari, 261 F.3d 853, 857-58 (9th Cir.2001) (citing Verduzco v. Apfel, 188 F.3d 1087, 1089 (9th Cir.1999)). While “ ‘expressions of impatience, dissatisfaction, annoyance, and even anger’ ” by themselves “do not establish bias,” Rollins, 261 F.3d at 858 (quoting Liteky v. United States, 510 U.S. 540, 555-56 , 114 S.Ct. 1147 , 127 L.Ed.2d 474 (1994)), a claimant may rebut the presumption that an ALJ is unbiased if he shows that “the ALJ’s behavior, in the context of the whole case, was ‘so extreme as to display clear inability to render fair judgment.’ ” Id. (quoting Liteky, 510 U.S.…