{"id":505,"date":"2026-01-20T12:00:00","date_gmt":"2026-01-20T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=505"},"modified":"2026-01-20T12:00:00","modified_gmt":"2026-01-20T12:00:00","slug":"lindsey-cf-bisignano-cd-cal-disability-denial-symptom-testimony-caregiving-daily-activities","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=505","title":{"rendered":"Lindsey C.F. v. Bisignano \u2014 C.D. Cal. Affirms Disability Denial, Citing Caregiving Work, Treatment Gaps, and Active Daily Life"},"content":{"rendered":"
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Case<\/dt>\n
Lindsey C.F. v. Frank Bisignano, Commissioner of Social Security<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Central District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-20<\/dd>\n
Docket No.<\/dt>\n
2:25-cv-04721-JC<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Social Security, disability, subjective symptom testimony, daily activities, caregiving work, course of treatment, paid caregiving, Smartt, Trevizo<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Lindsey C.F. applied for Social Security benefits in April 2022. The administrative law judge (ALJ) denied her claim, finding that despite her impairments she retained the residual functional capacity (RFC) to perform a range of work. The ALJ partially discredited her testimony that she could not work due to severe pain and depression, that she could sit for only five minutes and stand for only three minutes, and that she had upper extremity limitations.<\/p>\n

Lindsey sought judicial review under 42 U.S.C. \u00a7 405(g), arguing the ALJ had not given clear and convincing reasons for discounting her testimony.<\/p>\n

The Court’s Holding<\/h2>\n

The court affirmed. Applying the Ninth Circuit\u2019s \u201cmost demanding\u201d clear-and-convincing standard, the court found the ALJ identified independently valid reasons for the credibility finding, each supported by substantial evidence.<\/p>\n

First, the ALJ relied on inconsistencies between Lindsey\u2019s testimony and her course of treatment \u2014 particularly her gaps in pursuing care for the conditions said to be disabling. Under Tommasetti v. Astrue, an unexplained or inadequately explained failure to seek treatment can weigh against a claimant\u2019s credibility.<\/p>\n

Second, the ALJ properly relied on Lindsey\u2019s daily activities, which the court found arguably contradicted her assertion of totally debilitating symptoms. Most pointedly, Lindsey was paid for caring for her aunt 73 hours per month \u2014 performing light housework and cleaning her aunt\u2019s stoma \u2014 and was helping her son with home schooling. She also reported to consulting and treating providers that she did household chores, ran errands, shopped alone, prepared meals without help, and went for short walks. She told her therapist she was working to access water aerobics. By June 2023, she reported to another doctor that she had been more active, was sleeping well, had started walking the dog, was gardening, doing more activities around the house, and had bought roller skates and was skating with her son.<\/p>\n

Under Smartt v. Kijakazi and Trevizo v. Berryhill, daily activities can support an adverse credibility finding when they contradict the claim of a totally debilitating impairment. The court emphasized that Smartt-style daily activities need not show that the claimant could perform full-time work \u2014 just that the testimony exaggerated the severity of the limitations.<\/p>\n

Because the ALJ\u2019s reasoning was specific, supported, and reasonable, the court declined to second-guess the credibility determination and affirmed.<\/p>\n

Key Takeaways<\/h2>\n