The following excerpt is from Parker v. Berryhill, No. 15-16936 (9th Cir. 2017):
The opinion of a non-examining physician cannot by itself constitute substantial evidence that justifies the rejection of an opinion of an examining physician. Tonapetyan v. Halter, 242 F.3d 1144, 1149 (9th Cir. 2001); Lester, 81 F.3d at 831. The opinion of a non-examining physician may qualify as substantial evidence only if other independent evidence in the record supports the opinion. Id.
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