Abrew

MEMORANDUM **

John Abrew (“Abrew”) appeals the Commissioner’s determination that he is *569 not disabled. The district court had jurisdiction under 42 U.S.C. § 405 (g) and affirmed the ALJ’s determination. We have jurisdiction under 28 U.S.C. § 1291 and we affirm.

Abrew is incorrect that his depression and anxiety are necessarily severe impairments simply because the Commissioner found him disabled before a change in the law made drug and alcohol addiction a legally insufficient basis for disability benefits. See 42 U.S.C. § 423 (d)(2)(C); see also Pub.L. No. 104-121 § 105 (requiring Commissioner to allow individuals disabled because of drug and alcohol addiction to reapply for benefits on a different basis). The ALJ properly found these impairments not severe because medical evidence showed that Abrew was well-oriented and could complete simple tasks. See Smolen v. Chater, 80 F.3d 1273, 1284 (9th Cir.1996) (holding that ALJ must evaluate symptom testimony by considering the factors in SSR 88-13, including observations of examining physicians).

In calculating Abrew’s residual functioning capacity (“RFC”), the ALJ gave specific, clear and convincing reasons for rejecting Abrew’s…