Background
Griselda Brambila appealed an order affirming an administrative law judge’s denial of her application for supplemental security income under Title XVI of the Social Security Act. The district court had affirmed the denial, but Brambila argued the judge erred in evaluating medical source opinions and the limiting effects of her migraines and psychogenic non-epileptic seizures.
The court’s reasoning
The court concluded the administrative law judge materially erred in assessing the claimant’s migraines and psychogenic non-epileptic seizures. Regarding migraines, the judge lacked substantial evidence to claim inconsistencies in the record and failed to account for the totality of medical evidence. Regarding psychogenic non-epileptic seizures, the judge described the diagnosis but did not evaluate how the episodes affected the claimant’s ability to work. The court found these errors were not harmless given vocational expert testimony that such conditions would prevent full-time unskilled work.
The [ALJ’s] disability determination should be upheld unless it contains legal error or is not supported by substantial evidence.
Orn v. Astrue, 495 F.3d 625, 630 (9th Cir. 2007)
What it means going forward
The decision requires the administrative law judge to calculate and award benefits to the claimant based on the fully developed record.