Elizabeth Delahoussaye v. Nancy E. Berryhill
Published: Nov. 22, 2019 | Result Date: Mar. 5, 2019 |Case number: 2:17-cv-2701-EFB Summary Judgment – Defense
Judge
Court
USDC Eastern District of California
Attorneys
Plaintiff
Paul H. Saltzen
(Paul H. Saltzen, Attorney at Law)
Defendant
Ellinor R. Coder
(Social Security Administration)
Edward A. Olsen
(Office of the U.S. Attorney)
Facts
Elizabeth Delahoussaye sought judicial review of the Commissioner of Social Security's denial of her application for a period of disability and disability insurance benefits.
Contentions
PLAINTIFF'S CONTENTIONS: Delahoussaye contended the ALJ improperly limited review of medical records without failing to consider the record as a whole. Delahoussaye also argued the ALJ erred in weighing medical evidence by giving great weight to non-examining physicians' opinions and giving little weight to the opinion of her primary care physician. Further, Delahoussaye contended additional evidence supplied related to the relevant period and supported a finding of disability.
DEFENDANT'S CONTENTIONS: Defendant denied the contentions and sought to uphold the Commissioner's decision.
Result
The court granted defendant's motion for summary judgment and denied Delahoussaye's motion for summary judgment. The court found the ALJ did consider the longitudinal record as a whole, reflected in his statements that he reviewed and considered Delahoussaye's complete medical history, and citations to records outside the limited period Delahoussaye claimed. The court also found Delahoussaye's primary care physician's opinion was properly given little weight because his findings did not relate to a disability proceeding and did not necessarily relate to the claims at hand. Further, the court found additional evidence Delahoussaye supplied contained records falling well outside the disability period such that they did not undercut the ALJ's findings.
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