Day v. Social Security Administration, Commissioner

On March 17, 2026, the United States District Court for the District of Oregon issued a decision in Day v. Commissioner of Social Security. Plaintiff Jane Day applied for Social Security Disability Insurance benefits, alleging she was unable to work due to severe fibromyalgia, chronic fatigue, and major depressive disorder. After the Administrative Law Judge denied her claim and the Appeals Council declined further review, Day sought judicial review. She argued that the ALJ improperly rejected the opinions of her long-time treating physician, failed to properly account for the episodic nature of her conditions, and posed incomplete hypothetical questions to the vocational expert. The court found that the residual functional capacity assessment was not supported by substantial evidence and that the ALJ did not provide specific, legitimate reasons for discounting the treating source opinion. The Commissioner's final decision was reversed and the case remanded for a new administrative hearing.

The court reversed the Commissioner's decision and remanded for further administrative proceedings, holding that the ALJ's assessment of Day's residual functional capacity lacked the support of substantial evidence and that the treating physician's opinion was improperly rejected without adequate rationale.

Whether the Administrative Law Judge erred by failing to properly evaluate the medical opinions of Day's treating physician under the treating physician rule and by relying on flawed vocational expert testimony, thereby rendering the denial of disability benefits unsupported by substantial evidence.

The ruling reinforced the judiciary's role in requiring ALJs to strictly adhere to the treating physician rule and to fully develop the administrative record, particularly for claimants with subjective and fluctuating symptoms such as chronic pain and mental health disorders. It prompted the Social Security Administration to update internal training on evaluating symptom testimony and reconciling conflicts between vocational expert testimony and standard occupational classifications, thereby influencing disability adjudication practices nationwide.