Case Explained: BRAMBILA V. BISIGNANO

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-15

Docket: 1:23-cv-03124-LRS

The Ninth Circuit reversed the district court’s affirmation of an Administrative Law Judge’s denial of supplemental security income benefits and remanded with instructions to calculate and award benefits to the claimant, Griselda Brambila. The court held that the ALJ committed material legal error in evaluating Brambila’s medical evidence regarding her migraines and psychogenic non-epileptic seizures (PNES). Regarding migraines, the court applied the two-step analysis from *Garrison v. Colvin*, requiring specific, clear, and convincing reasons to reject a claimant’s testimony about symptom severity when objective medical evidence supports an underlying impairment and there is no evidence of malingering. The court found the ALJ failed to provide such reasons because her rejection of Brambila’s testimony relied on “inconsistencies” that lacked substantial evidentiary support, including Brambila’s sporadic work history which did not reflect significant income, and a mischaracterization of medical records regarding migraine frequency. Regarding PNES, the court found the ALJ erred by merely describing the diagnosis without evaluating its actual impact on Brambila’s residual functional capacity or ability to work, specifically ignoring evidence of episodes causing unresponsiveness, breathing difficulties, and confusion. The practical consequence of this decision is that the case is remanded for the calculation and award of benefits rather than a new hearing. The court applied the “credit-as-true” rule, determining that the record was fully developed after two administrative hearings and that further proceedings would be unnecessary because crediting Brambila’s properly supported allegations regarding her migraines and PNES would necessitate a finding of disability due to the resulting absenteeism and off-task time exceeding vocational norms.

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