Sharon Molyneux v. Carolyn W. Colvin

MEMORANDUM

Sharon Molyneux (“Molyneux”) appeals the district court’s judgment affirming an Administrative Law Judge’s (“ALJ”) denial of her applications for Social Security disability benefits. After determining that Molyneux suffered from two severe impairments, the ALJ concluded that she had

the residual functional capacity (“RFC”) to perform light work (with some exceptions), including her past relevant work as a cashier. We have jurisdiction pursuant to 42 U.S.C. § 405 (g) and 28 U.S.C. § 1291 , and we affirm.

Molyneux contends that the ALJ made a number of errors in the course of examining the medical evidence, weighing her credibility, and assessing lay witness testimony. Most of the errors she cites in the ALJ’s consideration of the medical evidence are not errors at all. The only potential such error — the ALJ’s failure to address the report of state agency physician Dr. Clifford — is harmless, as that report is not inconsistent with the ALJ’s RFC assessment. Carmickle v. Comm’r., Social Sec. Admin., 533 F.3d 1155, 1162 (9th Cir.2008) (in assessing whether the ALJ’s error was harmful, “the relevant inquiry ... is not whether the ALJ would have made a different decision…