In Parsons v. Kijakazi, the U.S. District Court for the District of Arizona reversed the Social Security Administration's (SSA) denial of disability insurance benefits to Donald Parsons and remanded the case for further administrative proceedings. The court found that the administrative law judge (ALJ) failed to provide sufficient justification for discounting Parsons’ symptom testimony, which constituted reversible error.
Donald Parsons applied for Social Security Disability Insurance (SSDI) benefits in May 2018, alleging disability beginning in February of that year. After initial and reconsideration-level denials, Parsons received a hearing before an ALJ in September 2020. In a January 2021 decision, the ALJ found Parsons not disabled under the five-step evaluation process.
The ALJ determined that Parsons had several severe impairments, including a mild neurocognitive disorder, traumatic brain injury, degenerative disc disease, chronic headaches, pain disorder, and carpal tunnel syndrome. However, the ALJ concluded that Parsons retained the residual functional capacity (RFC) to perform light work and could engage in other jobs available in the national economy.
On appeal, Parsons challenged the ALJ’s rejection of a functional assessment provided by his treating physician, Dr. Keith Keating, and the dismissal of his own statements about chronic pain, headaches, and limitations in movement.
Dr. Keating had treated Parsons weekly since a 2013 motor vehicle accident. He opined that Parsons could stand for only 30 minutes, sit for two hours, and walk 100 feet without stopping. He also restricted Parsons to lifting no more than five pounds. The ALJ found these limitations extreme and inconsistent with the record, noting normal strength on examination, a lack of referral to specialists, and Parsons’ part-time work.
Parsons also testified to disabling headaches, balance issues, and chronic pain limiting daily activity. The court ruled that while conservative treatment might weigh against his claims, it did not alone justify discounting the testimony. The ALJ also failed to clearly connect specific parts of the medical record to the symptom testimony, violating the Ninth Circuit’s requirement for specific, clear, and convincing reasons to reject such evidence.
The court declined to award benefits outright. Instead, it remanded the case for further proceedings to allow the ALJ to reassess Parsons’ symptom testimony and RFC. The court emphasized that while the ALJ committed legal error, the record still left some doubt as to whether Parsons met the statutory definition of disability.
Claimants denied SSDI benefits have the right to appeal administrative decisions and challenge improper handling of medical evidence or symptom testimony. Our attorneys at Whitcomb, Selinsky, PC help clients pursue disability claims, address ALJ errors, and seek rehearings or remands when benefits are improperly denied.