Ninth Circuit Reaffirms ALJ Discretion in Putz v. Bisignano

The Ninth Circuit’s decision in Putz v. Bisignano (October 28, 2025) doesn’t change the law—but it reinforces what the court continues to expect when reviewing ALJ reasoning in Social Security disability cases.

Case Background

The claimant, Putz, appealed the denial of disability benefits. Both the district court and the Ninth Circuit affirmed the ALJ’s decision.The familiar issues included:

• Evaluation of medical opinions

• Symptom testimony

• Lay witness statements

• Residual Functional Capacity (RFC) assessment

  
  

Medical Opinion Analysis

The claimant challenged several medical sources, but the court upheld the ALJ’s reasoning for each:

• Doctor’s statement: Sitting or standing worsened knee pain→ Not a medical opinion under 20 C.F.R. § 404.1513(a) because it described symptoms, not functional limitations.

• Nurse practitioner: Sedentary-work restrictions→ Properly rejected as inconsistent with normal strength, normal gait, and improvement under conservative treatment (consistent with Tommasetti).

• Psychologist: Difficulty with complex tasks→ Reasonably discounted due to lack of sustained mental health treatment and improvement with medication.

• Podiatrist: Recommended avoiding prolonged standing→ The court emphasized that recommendations ≠ mandatory limitations (Valentine).

  
  

Key takeaway: When the record shows normal objective findings and improvement with conservative care, the ALJ’s discretion is typically upheld.

Symptom Testimony

The Ninth Circuit affirmed the ALJ’s decision to reject the claimant’s severity testimony because:

• Medical exams did not support the alleged limitations.

• Symptoms improved with treatment.

• The claimant failed to identify ignored evidence on appeal.

  
  

Q&A: Symptom Testimony

Q: When can an ALJ discount symptom testimony?

A: When contradictions exist between the claimant’s testimony and the medical record.

Lay Witness Statements

The claimant’s sister’s testimony was discounted for the same reasons as the claimant’s own statements—lack of consistency with objective findings and treatment evidence.

Key Lessons for Practitioners

✅ Improvement with conservative treatment remains a strong basis for discounting both medical opinions and symptom testimony.

✅ Recommendations ≠ functional limitations.

✅ Consistency with examination findings continues to drive persuasive value under post-2017 medical opinion rules.

Practical Takeaway

When the ALJ documents:

• Normal physical and mental exam findings

• Conservative treatment

• Symptom improvement

  
  

…the Ninth Circuit will generally defer to the ALJ’s discretion.

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