Armstrong v. Bisignano – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the denial of disability benefits, holding that the Administrative Law Judge did not err in discounting the claimant's testimony regarding headache severity due to contradictions with medical records and daily activity reports.
Standard: Substantial evidence review
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: This decision reinforces the standard that claimants must provide consistent testimony supported by medical evidence to prove the severity of subjective symptoms in Social Security disability cases.

The Ninth Circuit affirmed a district court judgment upholding the Social Security Commissioner's denial of disability benefits. The court held that the Administrative Law Judge properly discounted the claimant's testimony regarding headache severity based on specific, clear, and convincing evidence of contradictions.

Background

Amanda Armstrong appealed a district court judgment affirming the Social Security Commissioner’s denial of her application for disability benefits. The appeal focused on whether the Administrative Law Judge improperly discounted Armstrong’s testimony regarding the severity of her headaches.

The court’s reasoning

The court reviewed the Administrative Law Judge’s decision for substantial evidence or legal error. The court found that the Administrative Law Judge provided specific, clear, and convincing reasons for discounting Armstrong’s testimony. These reasons included discrepancies between Armstrong’s testimony about debilitating symptoms and her reported ability to perform daily activities such as crocheting, painting, and cooking. Additionally, the court noted contradictions between Armstrong’s testimony and her medical records, which showed variable headache frequency and reports of reduced symptoms with medication. The court also affirmed that the Administrative Law Judge properly considered Armstrong’s failure to follow prescribed treatment and normal physical examination findings that did not support claims of debilitating symptoms.

Contradiction with the medical record is a sufficient basis for rejecting the claimant’s subjective testimony.

Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155, 1161 (9th Cir. 2008)

What it means going forward

This decision reinforces the standard that claimants must provide consistent testimony supported by medical evidence to prove the severity of subjective symptoms in Social Security disability cases.