By Payroll and Entitlements Editorial Staff
An ALJ’s credibility assessment of a claimant’s pain testimony is important because such testimony is inherently subjective. Here, the ALJ discounted the claimant’s testimony regarding his pain because she found that the claimant had engaged in drug-seeking behavior. The court concluded that substantial evidence supported that finding. There was evidence that the claimant terminated his relationship with a treating physician after the doctor declined to prescribe additional pain medication. In addition, when the claimant sought to receive pain medication through the emergency room, the ER staff refused his request, noting that an information alert showed excess pain medication being filled by multiple providers statewide. Moreover, the medical record reflected conduct by the claimant that was inconsistent with his subjective complaints. Given the substantial evidence, the ALJ provided a clear and convincing reason to discount the claimant’s pain testimony. Regardless, even if the claimant’s explanation for his behavior was a rational one, the court reiterated that it would not disturb the ALJ’s differing rational interpretation where the interpretation is adequately supported. Furthermore, the weight afforded to the medical opinions by the ALJ was supported by specific reasons. The ALJ did not err in concluding that the opinions assessing severe limitations were unsupported by the record. Noting that several sources relied on the claimant’s self-reports of pain, the ALJ did not err in discounting the medical opinions. The denial of benefits was affirmed (Travis Coleman v. Commr, CA-9, No. 19-35700, November 2, 2020).
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