Britton v. Colvin

An administrative law judge may disregard medical opinions that are brief, conclusory, and inadequately supported by clinical findings.

Gina Britton filed for Social Security Disability Insurance Benefits due to several ailments, which she claimed greatly impacted her ability to work, along with other necessary daily functions. The administrative law judge found that Britton was not as limited as she claimed, and based on testimony from a vocational expert, Britton could perform several jobs that she had held in the past. The administrative law judge therefore denied disability benefits for Britton. Review by the Social Security Appeals Council was also denied, which the district court affirmed. On appeal, the Ninth Circuit determined that the administrative law judge “reasonably accorded little weight” to the medical opinions presented within the record because the medical condition cited by Britton’s doctor was not included as a listed disability for eligibility of benefits. The panel noted that medical opinions that are “brief, conclusory, and inadequately supported by clinical findings” can be disregarded by an administrative law judge. The panel also found that the testimony by a nurse practitioner was not sufficient since a nurse practitioner is an unacceptable medical source. The panel noted that testimony from “other sources,” such as a nurse practitioner, can be discounted by an administrative law judge if given adequate reason. The panel concluded that the administrative law judge had good reason to discount the testimony and deny disability benefits since Britton was able to do light work based on the daily activities she was still able to perform. AFFIRMED.