The Ninth Circuit Court of Appeals has reversed part of a lower court's ruling regarding Kristin Collard's application for disability insurance benefits. This decision, filed on September 23, 2026, affects individuals seeking disability benefits under the Social Security Act, especially those with subjective ailments like fibromyalgia and migraines.
Collard's case began when she applied for disability insurance benefits in October 2016, claiming she was unable to work due to severe pain from fibromyalgia, migraines, and degenerative disc disease. She argued that her conditions had worsened over time, which made it impossible for her to continue working. The administrative law judge (ALJ) initially denied her claim, stating that Collard's testimony and supporting evidence were not credible. This led to an appeal to the Ninth Circuit.
The parties involved in this case are Kristin Collard, the plaintiff and appellant, and Frank Bisignano, the Commissioner of Social Security, who is the defendant and appellee. The case reached the Ninth Circuit after the district court affirmed the ALJ's decision to deny Collard's application for benefits. The Ninth Circuit panel included Judges Michael Daly Hawkins, M. Margaret McKeown, and Morgan B. Christen, with Judge McKeown writing the opinion.
The Ninth Circuit's ruling highlighted several errors made by the ALJ in evaluating Collard's claim. The court found that the ALJ incorrectly characterized Collard's work history, suggesting that her ability to work a strenuous job in the past undermined her claims of disability. The court stated, "A past ability to work through pain can be entirely consistent with testimony of worsening impairments that become disabling over time." This indicates that the court believes a history of employment should not automatically disqualify someone from receiving benefits if their condition has worsened.
Additionally, the court noted that the ALJ failed to properly analyze Collard's daily activities and did not adequately consider the evidence provided by family members and coworkers. The Ninth Circuit emphasized that the ALJ's reasoning was flawed, stating, "The mere fact that a plaintiff has carried on certain daily activities does not detract from her credibility." The court ordered a reevaluation of Collard's testimony and the lay evidence from her family and coworkers.
While the Ninth Circuit affirmed the ALJ's evaluation of medical opinion evidence from Collard's treating physicians, it reversed the decision regarding her subjective testimony and lay evidence. The court ruled that the ALJ's errors were prejudicial and warranted a new disability determination.
This ruling is significant as it clarifies how subjective testimony and lay evidence should be evaluated in disability claims. The court's decision may set a precedent for future cases involving applicants with similar conditions, emphasizing that a consistent work history should not automatically negate claims of worsening disability. The ruling also reinforces the importance of considering all evidence, including lay testimony, in determining a claimant's eligibility for benefits.
Going forward, this ruling means that individuals like Collard, who suffer from conditions that are difficult to quantify with objective medical evidence, may have a better chance of receiving disability benefits. The case underscores the need for ALJs to carefully evaluate all aspects of a claimant's situation, including their work history and personal accounts of their limitations.
As for what’s next, the case has been remanded for further proceedings, meaning that the ALJ will need to reevaluate Collard's application for benefits based on the Ninth Circuit's guidance. It remains to be seen whether the ALJ will reach a different conclusion after considering the court's findings. There are no indications in the opinion that the ruling will be appealed further.