Background
Kristin Collard applied for disability insurance benefits in October 2016, alleging disability beginning that June. She had worked for 11 years as a hospital patient care technician, a physically demanding job involving 12-hour shifts, extended time on her feet, and frequent lifting of 50 pounds or more.
Collard alleged limitations from fibromyalgia, migraines, and degenerative disc disease. She testified that worsening symptoms left her weak and exhausted, limited her ability to stand, sit, lift, and use her hands, and led her to take a voluntary layoff rather than medical leave. Her husband, niece, co-worker, and sister-in-law offered similar accounts. The ALJ found Collard capable of light work and denied benefits; the district court affirmed.
The Court’s Holding
The Ninth Circuit affirmed in part, reversed in part, and remanded for further proceedings. The ALJ improperly discounted Collard’s symptom testimony by treating her earlier ability to work through pain as evidence that her later-worsened impairments were not disabling. The court held that a claimant’s past work despite impairments can be consistent with testimony that those impairments became disabling over time.
The ALJ also inadequately relied on Collard’s daily activities and purportedly effective treatment. Merely listing activities without addressing qualifying evidence did not show she could perform work-like activities for a substantial part of the day, and partial relief from medications and other treatments did not establish that she overstated her symptoms. The same errors required reconsideration of the supporting lay testimony. But substantial evidence supported the ALJ’s rejection of the treating physicians’ opinions as conclusory or inadequately supported, so the court affirmed that portion of the decision.
Key Takeaways
- An ALJ may not treat a claimant’s prior ability to work through pain as a clear and convincing reason to reject evidence that symptoms later worsened and became disabling.
- Daily activities must be meaningfully connected to work capacity; a bare list of activities is insufficient.
- For fibromyalgia, an ALJ cannot discount symptom testimony merely because examinations or objective tests show few abnormalities.
Why It Matters
The decision reinforces that a sustained work history should not become a logical trap for disability claimants who continue working until progressive or worsening conditions force them to stop. It also emphasizes the Ninth Circuit’s demanding requirements for rejecting subjective symptom testimony where there is no evidence of malingering.
On remand, the agency must reevaluate Collard’s testimony and the corroborating lay evidence, and make a new disability determination without relying on the flawed rationales identified by the court.