Missteps in SSDI Ruling Lead to Reversal

Let’s talk about Walls v. Bisignano, a case that highlights the continued tension between ALJ discretion and the requirement for accurate, reasoned analysis of the medical record.

🧑‍⚖️ What happened? Mr. Walls applied for disability insurance benefits. The ALJ denied the claim, finding one doctor’s opinion “inconsistent” with treatment notes, questioning the claimant’s use of a cane, and citing “benign imaging” as a basis to discount symptom severity.

But here’s the twist:

👉 The ALJ confused two medical providers—attributing Dr. Geffen’s statements to Dr. Novotney.

👉 The ALJ also conflated different sources of pain (back vs. foot/leg pain due to obesity and diabetic neuropathy).

👉 He failed to address why Walls may have been noncompliant with certain treatments, and didn’t link that noncompliance to his reported pain.

⚖️ The Ninth Circuit’s take?

The court reversed, stating the ALJ’s rejection of medical opinions and symptom testimony wasn’t supported by substantial evidence and relied on legal error. The ALJ didn’t properly analyze the § 416.920c(c) factors or address inconsistencies with enough reasoning for meaningful review.

🔍 Key takeaways for practitioners:

1. Misattribution matters. You can't evaluate consistency when you're confusing two providers.

2. Pain is multifactorial. You can’t dismiss foot and leg pain with “benign” back imaging.

3. Subjective symptom testimony needs more than cherry-picked daily activity statements.

4. Noncompliance must be contextualized. You can't penalize claimants without analyzing why.

   
   

This decision reinforces that ALJs must be precise and thorough—especially when credibility and medical opinions are on the line.

Got any questions? Schedule a consultation with us. I’m here to help. It’s a lot to take in, but we’ll get through it together. After all, navigating these waters is always easier when you’ve got someone to chat with.