I have handled kids' disability claims, so I know how critical it is for ALJs to get it right. And even though these cases are not common, they are very important.
So, let’s talk about Knight v. Colvin, a 10th Circuit remand from 2014 (yep, a long time ago now) specifically because the ALJ failed to properly evaluate credibility, medical evidence, and functional limitations under the child disability listings.
🔹 The Case at a Glance
P.K., a minor, applied for SSI due to ADHD, a learning disability, and other mental health conditions. Despite evidence of significant impairments, including suicidal ideation, self-harm, and aggressive behavior, the ALJ found she was not disabled, concluding that her limitations were “less than marked.”
But the Tenth Circuit disagreed.
🔹 Where the ALJ Went Wrong
First, the ALJ failed to properly assess the credibility of P.K.’s mother’s testimony, dismissing it with generic language rather than making specific findings. Courts have made it clear: a parent's testimony in child cases must be evaluated just as the child’s would be.
Second, Dr. Hall, who treated P.K. for three years, found her extremely impaired in social functioning. The ALJ discounted this, claiming Dr. Hall relied too much on subjective reports and only managed medication. The court called this out. Long-term psychiatric care is valid medical evidence.
Third, to qualify under the child disability listing, a claimant must show an “extreme” limitation in one domain or “marked” limitations in two. The ALJ downplayed clear evidence of severe limitations in interacting with others and caring for oneself, despite documented self-harm and aggressive behavior.
🔹 Insights:
This case is a reminder that ALJs often misapply SSA’s childhood disability framework. When arguing these cases:
✅ Demand specific credibility findings, boilerplate language won’t cut it.
✅ Challenge the ALJ’s failure to give proper weight to treating physicians.
✅ Push for a thorough domain-by-domain analysis using SSR 09-1p’s “whole child” approach.
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.
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