{"id":405,"date":"2026-01-06T12:00:00","date_gmt":"2026-01-06T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=405"},"modified":"2026-01-06T12:00:00","modified_gmt":"2026-01-06T12:00:00","slug":"mitch-c-bisignano-cd-cal-reverses-ssi-symptom-testimony-schizoaffective","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=405","title":{"rendered":"Mitch C. v. Bisignano \u2014 C.D. Cal. Reverses Social Security SSI Denial for Failure to Provide Clear and Convincing Reasons to Discount Schizoaffective Symptom Testimony"},"content":{"rendered":"
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\n
Case<\/dt>\n
Mitch C. v. Bisignano<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Central District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-06<\/dd>\n
Docket No.<\/dt>\n
5:24-cv-02147<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Social Security disability appeal; subjective symptom testimony; clear-and-convincing standard; Brown-Hunter v. Colvin; mental-health impairments<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Plaintiff Mitch C. applied for Supplemental Security Income (SSI) in February 2022, alleging disability beginning November 2019. He was diagnosed with schizoaffective disorder (bipolar type), major depressive disorder, and substance addiction disorders with stimulant-induced psychosis (in reported remission). The Administrative Law Judge found these were severe impairments but concluded Mitch C. retained the residual functional capacity (RFC) to perform work at all exertional levels with various nonexertional limitations and could perform jobs like hospital cleaner, laundry worker, and hand packer. The ALJ discounted Mitch’s subjective symptom testimony as inconsistent with the medical evidence.<\/p>\n

Mitch C. sought judicial review under 42 U.S.C. \u00a7 405(g), challenging both (1) the ALJ’s rejection of his subjective symptom testimony and (2) the ALJ’s failure to evaluate the treating-source opinion of Dr. David Dobos.<\/p>\n

The Court’s Holding<\/h2>\n

Magistrate Judge Maria A. Audero reversed the Commissioner’s decision and remanded for further administrative proceedings. The court held that the ALJ failed to provide the “specific, clear and convincing” reasons required by Ninth Circuit precedent (Garrison v. Colvin; Brown-Hunter v. Colvin) to reject Mitch C.’s symptom testimony.<\/p>\n

The clear-and-convincing standard is “the most demanding required in Social Security cases.” The ALJ’s general statements that the testimony was inconsistent with the medical evidence \u2014 without identifying which specific testimony was being rejected and which evidence contradicted it \u2014 were insufficient. Particularly in mental-health cases, where symptoms cycle and waver, ALJs cannot rely on isolated periods of improvement or limited daily activities to discount the claimant’s account of debilitating symptoms. Because the symptom-testimony error required remand, the court declined to reach the second issue (the ALJ’s failure to evaluate Dr. Dobos’s opinion).<\/p>\n

Key Takeaways<\/h2>\n