Ochoa

Ochoa v. Martin O'Malley

Good Law
United States District Court, Northern District of CaliforniaApril 4, 20243:23-cv-04857California667 words

Opinion

Trial Court Opinion

facts, the applicable legal standard, and the arguments made by the parties. 1. When assessing the claimant’s residual functional capacity, the ALJ needed to consider “all” of her medically determinable impairments, including impairments that the ALJ concluded were “not severe.” 20 C.F.R. § 404.1545(a)(2); see also Loader v. Berryhill, 722 F. App’x 653, 654–55 (9th Cir. 2018). But the ALJ neglected to consider the claimant’s mental impairments when assessing her RFC: The ALJ did not mention any mental impairments beyond step two of the evaluation process. The ALJ did not include any limitations reflecting the claimant’s mental impairments in her RFC. And the ALJ did not specify why the claimant’s mental impairments did not limit her ability to work. Instead, the ALJ merely asserted that the RFC assessment “reflects the degree of limitation” found in the ALJ’s analysis at step two. But the ALJ needed to say more. An impairment that is not severe can still limit a claimant’s ability to work, especially when considered in combination with the claimant’s other impairments. That is why the evaluation process calls for “a more detailed assessment” of mental impairments at the RFC stage…

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