Mazon v. SSA: Conservative Care Undermined Disability Claim

In Mazon v. Commissioner of Social Security, the U.S. District Court for the Eastern District of California upheld the denial of disability insurance benefits to Carla Roxanne Mazon. The court found that the administrative law judge (ALJ) properly evaluated the medical evidence and gave clear and convincing reasons for rejecting the extent of Mazon’s subjective symptom testimony.

SSDI Claim and Administrative Findings

Mazon filed for disability benefits in 2019, alleging that she became disabled on January 1 of that year. After her claims were denied at the administrative levels, she received a hearing before an ALJ in February 2021. The ALJ found that Mazon suffered from several severe impairments including fibromyalgia, degenerative disc disease, depressive disorder, post-traumatic stress disorder, and obesity. However, the ALJ determined that Mazon retained the residual functional capacity (RFC) to perform light work with certain physical and mental limitations.

The ALJ concluded that Mazon could return to past relevant work as a routing clerk. As a result, the Social Security Administration denied her application for benefits.

Plaintiff’s Challenge to Symptom Rejection

Mazon challenged the denial in federal court, arguing that the ALJ failed to properly consider her subjective reports of pain and mental limitations. She claimed the ALJ erred by not including sufficient work-related limitations in the RFC assessment and failed to articulate valid reasons for rejecting her symptom testimony.

The court acknowledged that Mazon experienced persistent symptoms, including pain and mental health difficulties. However, the ALJ found that her course of treatment had been largely conservative, with some improvement on medication, and that she had only intermittent mental health treatment. In addition, her activities of daily living—such as childcare and housework—were cited as inconsistent with the level of functional impairment she alleged.

The ALJ also relied on prior administrative medical findings and consultative examinations that supported Mazon’s ability to perform modified light work. The court emphasized that while objective evidence need not fully corroborate subjective complaints, inconsistency with such evidence is a valid basis to discount testimony.

Court’s Decision and Legal Standards

The district court affirmed the ALJ’s findings, concluding that:

• The ALJ applied the correct legal standard in evaluating symptom testimony under Smartt v. Kijakazi.

• The decision included sufficiently clear and convincing reasons for finding Mazon’s symptom statements not entirely consistent with the medical evidence.

• The ALJ properly considered the nature and effectiveness of Mazon’s treatment, inconsistencies in the record, and her reported daily activities.

While Mazon pointed to evidence of significant pain and symptoms, the court found that the ALJ’s conclusions were supported by substantial evidence and therefore not subject to reversal.

Legal Support for Social Security Disability Appeals

If you have been denied SSDI benefits due to a dispute over your symptom severity or RFC, our team at Whitcomb, Selinsky, PC can evaluate your case and assist you with appealing improper denials under SSA standards.