Opinion
5:23-cv-00382-MAA
12-15-2023
JUDY C.,[1] Plaintiff, v. KILOLO KIJAZAKI, Acting Commissioner of Social Security, Defendant.
MEMORANDUM DECISION AND ORDER AFFIRMING DECISION OF THE COMMISSIONER
HONORABLE MARIA A. AUDERO UNITED STATES MAGISTRATE JUDGE
I. INTRODUCTION
On March 7, 2023, Plaintiff Judy C. (“Plaintiff”) filed a Complaint seeking review of Defendant Commissioner of Social Security's (“Defendant” or “Commissioner”) final decision denying her application for a period of disability and disability insurance benefits (“DIB”) under Title II of the Social Security Act. (Compl., ECF No. 1.) Pursuant to 28 U.S.C. § 636(c), the parties consented to the jurisdiction of a United States Magistrate Judge. (ECF Nos. 7, 8.) On May 8, 2023, the Commissioner filed an Answer and the Administrative Record (“AR”). (ECF No. 12.) On June 8, 2023, Plaintiff filed a Brief in Support of Complaint (“Plaintiff's Brief”). (Pl's Br., ECF No. 14.) On September 8, 2023, Defendant filed Defendant Commissioner's Brief (“Defendant's Brief”). (Def's Br., ECF No. 22.) On May 13, 2023, Plaintiff filed a Reply to Plaintiff's Brief (“Reply”). (Reply, ECF No. 23.) The matter is fully briefed and the Court deems the matter appropriate for resolution without oral argument. See Fed.R.Civ.P. 78(b); C.D. Cal. L.R. 7-15. For the reasons discussed below, the Commissioner's final decision is affirmed, and this action is dismissed with prejudice.
II. SUMMARY OF ADMINISTRATIVE PROCEEDINGS
On July 16, 2019, Plaintiff filed an application for a period of disability and DIB, alleging disability beginning on November 13, 2017. (AR 236-44.) Plaintiff alleged she was disabled due to the following conditions: hip, knee, and foot injury; bilateral shoulders; glaucoma; osteoporosis; high blood pressure, cholesterol; borderline diabetic. (AR 165.) The Commissioner denied the application on September 27, 2019, and again upon reconsideration on February 6, 2020. (AR 165-69, 173-77.) On April 3, 2020, Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”). (AR 178-79.) At a telephonic hearing held on October 28, 2021, the ALJ heard testimony from Plaintiff, who represented herself, and a vocational expert. (AR 112-37.)
In a decision dated March 17, 2022, the ALJ denied Plaintiff's application after making the following findings under the Commissioner's five-step evaluation. (AR 93-111.) At step one, the ALJ found that Plaintiff had not engaged in substantial gainful activity since November 13, 2017, the alleged onset date. (AR 99.) At step two, the ALJ found that Plaintiff had severe impairments consisting of degenerative disc disease of the lumbar spine, mid-lateral labrum partial tear of the right hip, degenerative joint disease of the right knee status post surgical repair of meniscus tear, and diabetes mellitus with peripheral neuropathy of the right foot. (Id.) At step three, the ALJ found that Plaintiff did not have an impairment or combination of impairments that met or medically equaled the severity of one of the agency's listed impairments. (Id.) Next, the ALJ found that Plaintiff had the following Residual Functional Capacity (“RFC”):
[Plaintiff] has the residual functional capacity (RFC) to perform light work as defined in 20 CFR 404.1567(b) except she is limited to standing and walking for four hours total in an eight-hour workday while remaining capable of sitting for six hours total in an eight-hour workday. She is limited to pushing and pulling frequently with her bilateral upper and lower extremities. While she cannot climb ladders, ropes or scaffold, she can occasionally climb ramps or stairs, stoop, kneel, crouch and crawl as well as frequently balance.(AR 100.) At step four, the ALJ found that Plaintiff was capable of performing her past relevant work as a bookkeeper. (AR 105.) Accordingly, the ALJ concluded that Plaintiff was not disabled, as defined by the Social Security Act, from November 13, 2017 through the date of the decision on March 17, 2022. (AR 106.)
On January 25, 2023, the Appeals Council denied Plaintiff's request for review. (AR 1-7.) Plaintiff now seeks judicial review of the ALJ's decision, which stands as the final decision of the Commissioner. See 42 U.S.C. § 405(g).
III. STANDARD OF REVIEW
Pursuant to 42 U.S.C. § 405(g), the Court reviews the Commissioner's final decision to determine whether the Commissioner's findings are supported by substantial evidence and whether the proper legal standards were applied. See Treichler v. Comm'r of Soc. Sec. Admin., 775 F.3d 1090, 1098 (9th Cir. 2014). “‘Substantial evidence' means more than a mere scintilla, but less than a preponderance; it is such relevant evidence as a reasonable person might accept as adequate to support a conclusion.” Lingenfelter v. Astrue, 504 F.3d 1028, 1035 (9th Cir. 2007); see also Richardson v. Perales, 402 U.S. 389, 401 (1971). The Court “must consider the record as a whole, weighing both the evidence that supports and the evidence that detracts from the Commissioner's conclusion, and may not affirm simply by isolating a specific quantum of supporting evidence.” Trevizo v. Berryhill, 871 F.3d 664, 675 (9th Cir. 2017) (quoting Garrison v. Colvin, 759 F.3d 995, 1009 (9th Cir. 2014)). “‘Where evidence is susceptible to more than one rational interpretation,' the ALJ's decision should be upheld.” Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007) (quoting Burch v. Barnhart, 400 F.3d 676, 679 (9th Cir. 2005)). “If the evidence can support either affirming or reversing the ALJ's conclusion, [a court] may not substitute [its] judgment for that of the ALJ.” Robbins v. SSA, 466 F.3d 880, 882 (9th Cir. 2006).
IV. DISCUSSION
A. Disputed Issue
The parties raise the following single disputed issue: Whether the ALJ properly evaluated the opinions of Dr. Marc C. Hamilton, a treating chiropractor. (Pl's Br. 4; Def's Br. 4-7.)
With the exception of the Administrative Record, citations to pages in docketed documents reference the page numbers created by the CM/ECF headers.
B. Applicable Law
For claims, such as Plaintiff's claim, filed on or after March 27, 2017, an adjudicator “will not defer or give any specific evidentiary weight, including controlling weight, to any medical opinion(s) or prior administrative medical finding(s), including those from [a claimant's] medical sources.” 20 C.F.R. §§ 404.1520c(a), 416.920c(a). “For claims subject to the new regulations, the former hierarchy of medical opinions-in which we assign presumptive weight based on the extent of the doctor's relationship with the claimant-no longer applies. Now, an ALJ's decision, including the decision to discredit any medical opinion, must simply be supported by substantial evidence.” Woods v. Kijakazi, 32 F.4th 785, 787 (9th Cir. 2022).
The adjudicator “will articulate in [his or her] determination or decision how persuasive [he or she] find[s] all of the medical opinions and all of the prior administrative medical findings in [the claimant's] case record.” 20 C.F.R. §§ 404.1520c(b), 416.920c(b). “The factors of supportability . . . and consistency . . . are the most important factors[.]” 20 C.F.R. §§ 404.1520c(b)(2), 416.920c(b)(2). Thus, the adjudicator “will explain how [he or she] considered the supportability and consistency factors[.]” Id.
“Supportability means the extent to which a medical source supports the medical opinion by explaining the ‘relevant . . . objective medical evidence.'” Woods, 32 F.4th at 791 (quoting 20 C.F.R. § 404.1520c(c)(1)); see also 20 C.F.R. § 416.920c(c)(1). Supportability also means the extent to which the medical source presented “supporting explanations” for his or her medical opinion. 20 C.F.R. § 404.1520c(c)(1)); 20 C.F.R. § 416.920c(c)(1). “Consistency means the extent to which a medical opinion is ‘consistent . . . with the evidence from other medical sources and nonmedical sources in the claim.'” Woods, 32 F.4th at 791-92 (quoting 20 C.F.R. § 404.1520c(c)(2)); see also 20 C.F.R. § 416.920c(c)(2). While “ALJs should endeavor to use [the] terms of art-‘consistent' and ‘supported'- with precision,” it is possible to ascertain which factor the ALJ analyzed by looking at the context of the ALJ's reasoning. Woods, 32 F.4th at 793 n.4 (examining the ALJ's reasoning in context to determine whether it involved inconsistency or supportability).
C. Background
Dr. Hamilton began treating Plaintiff as part of her worker's compensation claim on December 7, 2018. (AR 351.) From late 2018 to December 2019, Dr. Hamilton assessed that Plaintiff was “temporarily totally disabled” for 30-day periods at a time. (AR 969, 972, 975, 979, 984, 988, 992, 996, 1000, 1004, 1009.) In late 2019, Dr. Hamilton assessed that Plaintiff was not a candidate for hip surgery and had reached maximum medical improvement, and recommended workplace accommodations to preclude repetitive weightbearing, kneeling, squatting, crawling, and climbing. (AR 1013-14.) From February to August 2020, Dr. Hamilton assessed that Plaintiff was “temporarily totally disabled” for 30-day periods at a time. (AR 1022, 1026, 1030.) In August and September 2020, Dr. Hamilton assessed that Plaintiff had the following work restrictions for a 30-day period: “no lifting more than five pounds; no prolonged bending, stooping, and twisting; avoid repetitive or prolonged weight bearing; no repeated kneeling or squatting; no crawling or climbing.” (AR 1042, 1049.) Beginning in February 2020, Dr. Hamilton noted Plaintiff's permanent work restrictions included preclusion from repetitive weightbearing, kneeling, squatting, crawling, or climbing and that Plaintiff was unable to return to her past work. (AR 1022, 1026, 1030, 1042, 1049.) On September 21, 2020, Dr. Hamilton reported that Plaintiff was “temporary partially disabled and able to return to work on 9/22/2020 with restrictions” including “no lifting more than five pounds; no prolonged bending, stooping, and twisting; avoid repetitive or prolonged weight bearing; no repeated kneeling or squatting; no crawling or climbing.” (AR 1049.)
D. Analysis
The ALJ analyzed Dr. Hamilton's opinions together with Plaintiff's other “worker's compensation doctors” and found them not fully persuasive. (AR 10405.) Each finding relating to Dr. Hamilton is reviewed in turn.
1. Limitations recommended for short periods of time
The ALJ first found that Dr. Hamilton's provision of “limitations for brief periods of time” and “30-day work restrictions . . . [were] not for a continuous 12 month period . . . [and therefore were] not determinative under the criteria for a finding of disability under the Social Security Act.” (AR 104 (citing AR 418-26, 457-59, 645, 1039-43, 1046-50).) The ALJ further found that Dr. Hamilton's conclusion that Plaintiff was “temporarily totally disabled” was “a term of art in worker's compensation law” that was not relevant to Plaintiff's application under the Social Security Act. (Id.)
An impairment is considered a “‘disability' if it ‘has lasted or can be expected to last for a continuous period of not less than 12 months.'” Taylor v. Kijakazi, No. 22-35724, 2023 U.S. App. LEXIS 22472, at *1 (9th Cir. Aug. 25, 2023) (unpublished) (citing 42 U.S.C. § 423(d)(1)(A)). A doctor's assessment of limitations that would not last more than twelve months is entitled to little weight. See Fisher v. Berryhill, 708 Fed.Appx. 384, 385 (9th Cir. 2017) (unpublished) (finding that a doctor's opinion did not indicate that the claimant's limitations would last more than twelve months and therefore was entitled to “little weight”) (quoting Garrison, 759 F.3d at 1010); Taylor, 2023 U.S. App. LEXIS 22472, at *1 (finding substantial evidence supported the ALJ's finding that doctor's opinion was unpersuasive because the assessed limitations would “last less than twelve months, not satisfying the statutory duration period”). In addition, “[w]orkers' compensation disability ratings are not controlling in disability cases decided under the Social Security Act, and the terms of art used in the California workers' compensation guidelines are not equivalent to Social Security disability terminology.” Booth v. Barnhart, 181 F.Supp.2d 1099, 1104 (C.D. Cal. 2002); see 20 C.F.R. § 404.1504 (“Because a decision by any other governmental agency or a nongovernmental entity about whether [a claimant is] disabled . . . is based on its rules, it is not binding on [the Social Security Administration] and is not our decision about whether you are disabled or blind under [its] rules.”)
Here, a review of the record confirms that Dr. Hamilton recommended limitations on Plaintiff's ability to work for 30-day periods at a time. (AR 969, 972, 975, 979, 984, 988, 992, 996, 1000, 1004, 1009, 1030.) Though Plaintiff argues that Dr. Hamilton imposed the temporary work restrictions consistently over the course of treating Plaintiff, such that “it is reasonable to conclude that those limitations extend back to at least the first date of treatment,” the record belies such a finding. (Reply 3.) Dr. Hamilton found that Plaintiff was “temporarily totally disabled” for 30-day periods from December 7, 2018 to December 20, 2019. (AR 357, 454, 459, 969, 975, 979, 984, 988, 992, 996, 1000, 1004, 1009.) Beginning on December 18, 2019, however, Dr. Hamilton no longer included such restrictions, and instead recommended certain accommodations in Plaintiff's work. (AR 101314, 1018.) From February to August 2020, Dr. Hamilton assessed that Plaintiff was “temporarily totally disabled” for 30-day periods of time. (AR 1022, 1026, 1030, 1042.) However, on September 21, 2020, Dr. Hamilton reported that Plaintiff was “able to return to work on 9/22/2020 with restrictions” including no lifting more than five pounds; no prolonged bending, stooping, and twisting; avoid repetitive or prolonged weight bearing; no repeated kneeling or squatting; no crawling or climbing. (AR 1049.) Accordingly, the record reveals that Dr. Hamilton adjusted his assessed restrictions throughout Plaintiff's visits, rather than consistently applying the same restrictions throughout Plaintiff's treatment in a way that could be interpreted as permanent restrictions. (Compare AR 357, 454, 459, 969 (reflecting “temporary total disability”) with AR 1013-14, 1018, 1049 (assessing workplace accommodations rather than total disability)). Accordingly, the ALJ did not err in finding that Dr. Hamilton's temporary restrictions did not inform a finding of total, permanent disability under the Social Security Act. See Fisher, 708 Fed.Appx. at 385.
In addition, the ALJ was not bound by Dr. Hamilton's determination that Plaintiff was “temporarily totally disabled” because “[a] decision by any nongovernmental agency or any other governmental agency about whether you are disabled . . . is not [the Administration's] decision about whether [the claimant] is disabled.” 20 C.F.R. § 404.1504. Instead, ALJs makes their own disability “determination based on social security law.” Id. The ALJ was entitled to find Dr. Hamilton's assessment based in the worker's compensation context not probative to Plaintiff's claim of disability under the Social Security Act, and therefore reversal is not warranted based on this finding. See Blanco v. Colvin, No. SA CV 15-1656-SP, 2016 U.S. Dist. LEXIS 180052, at *24 (C.D. Cal. Dec. 29, 2016) (finding that “the ALJ correctly noted that temporary total disability is a term used in worker's compensation cases and does not apply in the social security disability context.”) (citing Booth, 181 F.Supp.2d at 1104)). The ALJ's finding that Dr. Hamilton's use of worker's compensation terms of art used in his opinions were not probative to his decision was supported by substantial evidence.
2. Not consistent with other medical opinions in the record
Next, the ALJ found that Dr. Hamilton's opinions were inconsistent with Dr. Azizollah Karamlou's opinion. (AR 104.) An ALJ considers “other medical sources” when analyzing whether a medical opinion is consistent with the other evidence in the record. 20 C.F.R. § 404.1520c(c)(2); 20 C.F.R. § 416.920c(c)(2). An ALJ may find a medical opinion inconsistent with other medical opinions in the record. See Woods, 32 F.4th at 793 (finding substantial evidence supported an inconsistency finding where an ALJ pointed to observations from another medical source); Cindy L.B. v. Comm'r of Soc. Sec., No. 1:20-cv-00558-AA, 2022 U.S. Dist. LEXIS 191533, at *12 (D. Or. Oct. 20, 2022) (finding medical opinion unpersuasive because it was inconsistent with other medical opinions in the record).
Here, the ALJ appropriately considered other medical opinions, such as Dr. Karamlou, in analyzing whether Dr. Hamilton's opinion was consistent with other medical sources in the record. See 20 C.F.R. § 404.1520c(c)(2); 20 C.F.R. § 416.920c(c)(2). Dr. Karamlou assessed Plaintiff's abilities in September 2019 and found that she was able to frequently push, pull, bend, stoop, kneel, and crawl. (AR 692; see AR 103.) This finding was inconsistent with Dr. Hamilton's assessments that Plaintiff was “temporarily totally disabled” in late 2018 and throughout 2019 (AR 357, 454, 459, 969, 975, 979, 984, 988, 992, 996, 1000, 1004, 1009) and the December 18, 2019 assessment that Plaintiff was precluded from repetitive weightbearing, kneeling, squatting, crawling, or climbing (AR 1013-14). The ALJ's finding that Dr. Hamilton's opinion was inconsistent with the opinion of Dr. Karamlou was supported by substantial evidence. See Cindy L.B., 2022 U.S. Dist. LEXIS 191533, at *12.
3. Terminology is vague
Next, the ALJ found that certain terms used by Dr. Hamilton in limiting Plaintiff to “semi-sedentary work with no prolonged standing and walking and no climbing” and precluding Plaintiff from “repetitive weight bearing, kneeling, squatting, crawling or climbing” were vague, such as the terms “prolonged” and “repetitive.” (AR 104 (citing AR 1011-15).) The ALJ's finding, in context, went to the factor of supportability because it conveyed that Dr. Hamilton's opinion was not accompanied by supporting explanations. See Woods, 32 F.4th at 793 n.4 (examining the ALJ's reasoning in context to determine whether it involved inconsistency or supportability); 20 C.F.R. § 404.1520c(c)(1); 20 C.F.R. § 416.920c(c)(1) (supportability means, inter alia, the extent to which the medical source presented “supporting explanations” for his or her medical opinion).
An ALJ permissibly finds a medical opinion unsupported where the opinion fails “to assess any functional limitations.” Pernell v. Kijakazi, No. 21-35619, 2022 U.S. App. LEXIS 14105, at *2 (9th Cir. May 24, 2022) (finding substantial evidence supported the ALJ's decision to discount the opinion of a psychologist who relied on an outdated diagnostic framework and “failed to assess any functional limitations”); Ford v. Saul, 950 F.3d 1141, 1156 (9th Cir. 2020) (ALJ permissibly discounted a physician's opinion, under prior precedent governing the evaluation of medical opinions, where the descriptions in the opinion of the plaintiff's “ability to perform in the workplace as ‘limited' or ‘fair' were not useful because they failed to specify [the claimant's] functional limits.”); McLeod v. Astrue, 640 F.3d 881, 884-85 (9th Cir. 2011) (same where the physician's opinion merely stated that the claimant “could not work at all” without providing an evaluation of the claimant's “functional exertional capacity”).
Here, a review of Dr. Hamilton's opinion supports the ALJ's finding that the opinion used vague terms that were not vocationally relevant. (AR 104; see AR 1013, 1022, 1026, 1030, 1042, 1049.) Dr. Hamilton's assessments that Plaintiff be precluded from “prolonged” standing and walking and “repetitive weightbearing, repetitive kneeling, squatting, crawling or climbing” were not phrased in vocationally relevant terms that would allow the ALJ to analyze how the limitations would translate into a work setting. (See generally AR see AR 1013, 1022, 1026, 1030, 1042, 1049.) See Charquella G. v. Comm'r of Soc. Sec., No. C20-1148-MLP, 2021 U.S. Dist. LEXIS 79173, at *14 (W.D. Wash. Apr. 26, 2021) (finding that the ALJ did not err in discounting medical opinion that did not reference the claimant's “functional workplace limitations”). Thus, substantial evidence supported the ALJ's finding that Dr. Hamilton's opinion used vague terms that were not accompanied by helpful explanations.
4. Not supported by medical record showing mild abnormalities and improvement
The ALJ next found that Dr. Hamilton's opinions were not supported by his assessment that Plaintiff was not a candidate for hip surgery and that her right knee showed signs of improvement, and objective studies of her lumbar disorder showing mild abnormalities. (AR 104.) “Supportability means the extent to which a medical source supports the medical opinion by explaining the ‘relevant . . . objective medical evidence.'” Woods, 32 F.4th at 791 (quoting 20 C.F.R. § 404.1520c(c)(1)); see also 20 C.F.R. § 416.920c(c)(1). An ALJ may discount a medical opinion where it is unsupported by the physician's own clinical findings. See Kitchen v. Kijakazi, 82 F.4th 732, 740 (9th Cir. 2023) (affirming an ALJ's finding that a medical opinion was not persuasive where “objective observations during office visits counter[ed] the extremeness” of the opinion); Carolyn M. v. Comm'r, No. 6:22-cv-01715-HZ, 2023 U.S. Dist. LEXIS 183063, at *18-19 (D. Or. Oct. 6, 2023) (affirming ALJ's finding that physician's opinion was not supported by his own objective examinations).
Here, a review of the relevant objective medical evidence upon which Dr. Hamilton based his assessments reveals that the extent of the limitations he assessed for Plaintiff were not supported. (AR 351-355, 451-74, 493-967-1050.) Dr. Hamilton found that Plaintiff had mild abnormalities in her right hip, such that she was not a candidate for surgery and had reached maximum medical improvement. (AR 1013.) Moreover, Dr. Hamilton recorded that Plaintiff had “mild” pain in her right knee, and her knee no longer “lock[ed] or [gave] out following right knee arthroscopy.” (AR 452, 458, 464, 468, 472, 494, 506, 1012, 1017, 1021, 1025, 1029.) Dr. Hamilton also repeatedly found that Plaintiff had restricted range of movement in her back, with “slight antalgic component to the gait” and “Grade 2 tenderness.” (AR 355, 452, 458, 464, 472, 494, 506, 1012, 1017, 1021, 1025, 1029.) The ALJ reasonably concluded that these examination findings did not support the extent of Plaintiff's limitations captured in Dr. Hamilton's opinion. See Kitchen, 82 F.4th at 740; Carolyn M., 2023 U.S. Dist. LEXIS 183063, at *18-19. The ALJ's finding that Dr. Hamilton's opinion was not supported by his treatment notes showing mild abnormalities in Plaintiff's hip, improvement to Plaintiff's knee, and moderate or mild objective findings regarding Plaintiff's lumbar spine is supported by substantial evidence.
5. Inconsistent with Plaintiff's daily activities and evidence of conservative treatment
Finally, the ALJ found that Dr. Hamilton's opinion was inconsistent with Plaintiff's “statement from late 2021 that she had been able to carry her 20-pound grandchild as well as the lack of treatment after her worker's compensation claim was closed indicating that her symptoms were well managed with conservative homecare.” (AR 105.) The ALJ's finding conveyed that Dr. Hamilton's opinion lacked consistency with “the evidence from other medical sources and nonmedical sources in the claim.” See 20 C.F.R. § 404.1520c(c)(2); 20 C.F.R. § 416.920c(c)(2). An ALJ may permissibly find a medical opinion inconsistent with a claimant's admitted abilities and conservative course of treatment. See Rollins v. Massanari, 261 F.3d 853, 856 (9th Cir. 2001) (ALJ properly rejected a medical opinion that was “inconsistent with the [claimant's] level of activity” and “conservative course of treatment”); see also Jiminez v. Colvin, No. CV 12-01676-JEM, 2013 U.S. Dist. LEXIS 88614, at *14 (C.D. Cal. June 24, 2013) (“Infrequent, conservative treatment is not indicative of a disabling impairment.”).
Here, a review of the medical and nonmedical sources in the record confirms the ALJ's finding that Dr. Hamilton's opinion was not consistent with other evidence in the record. First, the ALJ reasonably found that Dr. Hamilton's opinions were inconsistent with evidence of Plaintiff's admitted abilities. (AR 105.) In late 2021, Plaintiff stated that she had been carrying her 20-pound grandchild (AR 911), which was inconsistent with Dr. Hamilton's assessment that Plaintiff be precluded from lifting no more than five pounds (AR 1042, 1049). See Mangrum v. Kijakazi, No. 1:20-cv-00932-BAM, 2023 U.S. Dist. LEXIS 27365, at *24 (E.D. Cal. Feb. 17, 2023) (finding substantial evidence supported ALJ's discounting of medical opinion as inconsistent with activities of daily living, including driving, doing chores, lifting ten to fifteen pounds, and reaching). Second, the ALJ reasonably found that the lack of treatment after Plaintiff's worker's compensation claim closed indicated that her symptoms were well managed with conservative homecare. (AR 105.) See Mangrum, 2023 U.S. Dist. LEXIS 27365, at *22-24 (upholding ALJ's discounting of medical opinion as inconsistent with symptoms that were controlled with conservative treatment and lack of further treatment in the record.) Plaintiff's worker's compensation case was closed in September 2020, and the record reflected no further treatment for her pain complaints. (AR 104, 911-15.) Plaintiff does not argue to the contrary. (See generally Pl's Br.; Reply.) Thus, substantial evidence supported the ALJ's consistency finding. See Rollins, 261 F.3d at 856.
D. Conclusion.
The ALJ properly considered the factors of consistency and supportability when discounting the medical opinions of Dr. Hamilton, and the ALJ's findings regarding Dr. Hamilton's opinion were supported by substantial evidence. Accordingly, reversal is not warranted.
V. ORDER
It is ordered that Judgment be entered affirming the decision of the Commissioner of Social Security and dismissing this action with prejudice.
IT IS SO ORDERED.