Zuniga v. Commissioner of Social Security

It’s that time of year when few court decisions are issued, the quiet stretch after the holidays. Yet, on December 26, 2019, the Ninth Circuit Court of Appeals released an important ruling in Zuniga v. Commissioner of Social Security, a case that continues to shape how Social Security disability appeals are reviewed.

Let’s break it down. 👇

Background of the Case

Zuniga appealed the denial of her Social Security disability benefits after two remands from the district court. By the time the case reached the Ninth Circuit, three major issues were at stake:

• The credibility of subjective symptom testimony

• The weight given to medical opinions

• Compliance with remand orders

  
  

1. Credibility of Subjective Symptom Testimony

Zuniga argued that the Administrative Law Judge (ALJ) unfairly discredited her testimony about the severity of her symptoms.

Using the two-step Vasquez test, the ALJ:

1. Acknowledged that Zuniga’s impairments could cause her symptoms.

2. Found inconsistencies between her statements, daily activities, and the medical evidence.

   
   

These inconsistencies led the ALJ to discount her credibility — a reminder that even consistent medical complaints must align with daily functioning and objective findings.

2. Weight of Medical Opinions

The ALJ also rejected opinions from Zuniga’s treating physicians—Drs. Rubin, Boorstein, and Lee—citing:

• Lack of objective medical support

• Overreliance on Zuniga’s self-reported symptoms

• Contradictions from daily activities and notes from a treating pharmacist

  
  

This demonstrates how courts continue to give deference to the ALJ’s discretion in weighing evidence, especially when treatment notes or daily activities appear inconsistent with reported limitations.

3. Compliance with Remand Orders

Zuniga further argued that the ALJ failed to comply with prior district court remand instructions — particularly regarding conflicting medical reports.

However, the Ninth Circuit upheld the ALJ’s decision, concluding that the remand instructions were adequately followed and that the findings were supported by substantial evidence.

Why Zuniga v. Commissioner Matters

This case is a masterclass in appellate deference. It highlights:

• The limited scope of appellate review in Social Security cases

• The importance of consistent medical documentation

• How daily activities can significantly influence credibility and outcomes

  
  

In short, when the ALJ’s decision is supported by “substantial evidence,” appellate courts rarely overturn it.

Q&A: Lessons for Practitioners

Q: What can claimants learn from this case?

A: Ensure medical documentation aligns with claimed limitations. Any inconsistencies — even small ones — can weaken credibility.

Q: How can attorneys strengthen appeals?

A: Focus on building a clear record that bridges subjective testimony with objective findings. Reconcile any discrepancies early in the process.

Q: What role do daily activities play?

A: They often serve as a reality check for credibility. Activities suggesting higher functional ability can undermine claims of severe impairment.

Final Takeaway

Zuniga v. Commissioner of Social Security underscores the importance of cohesive, evidence-based advocacy in disability cases. Whether preparing a hearing brief or an appellate argument, practitioners should focus on aligning:

• Claimant testimony

• Medical opinions

• Objective findings

Got any questions? Schedule a consultation with us. I’m here to help. It’s a lot to take in, but we’ll get through it together. After all, navigating these waters is always easier when you’ve got someone to chat with.