Parra v. Astrue

Joseph Parra (plaintiff) applied for Social Security benefits, claiming he was disabled because of liver cirrhosis due to alcohol abuse and bursitis. The applications were denied initially, upon reconsideration, and after an administrative-law judge (ALJ) hearing because the administration found that Parra was precluded from an award of benefits because his alcoholism was a material contributing factor to his disability. The decision was based on an administrative medical expert’s opinion, after reviewing Parra’s medical records, that the effects of Parra’s cirrhosis would have ceased had he quit drinking before his insurance lapsed. Parra sought judicial review of the denial, which became the first decision of the Commissioner of the Social Security Administration, Michael Astrue (defendant). A district court remanded the decision to the commissioner for reconsideration, then Parra died from several ailments including liver cirrhosis, and a second decision was rendered based on the same reasoning after Parra’s daughter had been substituted as the plaintiff. Parra’s daughter appealed, and the commissioner stipulated to a third ALJ hearing in which the ALJ found that, presuming Parra’s cirrhosis was disabling, he was precluded from a benefits award for the reasoning maintained from the commissioner’s initial decision. A district court affirmed the third denial, and Parra’s daughter appealed.