Daily activities can become part of a Social Security disability decision, especially when an administrative law judge finds that they conflict with testimony about severe limitations. In Douglas v. Bisignano, filed October 16, 2026, the Ninth Circuit affirmed the denial of Phyllis Douglas’s Disability Insurance Benefits claim.
The ALJ identified specific inconsistencies
Douglas testified about a tremor, a need for breaks, and reliance on other people for help. The ALJ compared that testimony with evidence that she could dress and groom herself, prepare simple meals, shop, drive, climb stairs, and complete household tasks. The ALJ also cited medical records indicating that medication controlled the tremor and that injections and over-the-counter medication improved lower-back pain.
The appellate panel held that these were clear and convincing reasons for discounting the claimed severity of the symptoms. It also found substantial evidence for an RFC allowing light work, including standing and walking for six hours per day. Because those findings stood, the vocational expert questions properly reflected the limitations the ALJ accepted.
Activity evidence needs context
An activity’s name rarely tells the whole story. A useful record explains how often the person performs it, how long it takes, whether assistance or breaks are required, and what symptoms follow. Shopping once with help differs from shopping independently on a predictable schedule. A simple meal differs from sustained standing, lifting, pace, and attendance in full-time work.
Treatment response also needs detail. “Improved” can describe short relief, partial relief, or restored function. Records can identify the duration of benefit, remaining symptoms, side effects, and whether improvement changes the ability to sustain work activities across a full day and week.
A federal appeal must identify the alleged error
Douglas also argued that the ALJ mishandled medical opinions, signs, and findings. The panel treated that argument as waived because the briefing did not identify a particular opinion, sign, or finding that was evaluated incorrectly. A focused appeal should point to the exact evidence, the legal or factual error, and the effect on the RFC or outcome.
This four-page memorandum is unpublished and nonprecedential except as Ninth Circuit Rule 36-3 permits. It does not establish that household activity always proves an ability to work, or that any improvement defeats a claim. The result depended on the reasons the ALJ gave and the evidence the panel found sufficient.
Source: Douglas v. Bisignano, No. 25-7283 (9th Cir. Oct. 16, 2026).
Learn more about Feden Law Group’s disability practice or schedule an initial consultation with an attorney.
You can also explore the FLG Claim Analyst (Beta).
This article provides general information, not legal advice. Reading it or requesting a consultation does not create an attorney-client relationship.