Case Citator › Karen Garrison v. Carolyn W. Colvin

Karen Garrison v. Carolyn W. Colvin

Is it still good law? What later courts have actually done to this case.

Superseded by statute
Court
Ninth Circuit
Citation
759 F.3d 995
Decided
Confirmed treatments
3
Flagged citations read
226 of 226
Citing cases (total)
226
Treatment dates
2022–2023
Superseded by statute
A reviewed court treats this case as superseded by later legislation. Garrison v. Colvin's medical opinion hierarchy and its “specific and legitimate reasons” standard were displaced for Social Security claims filed on or after March 27, 2017. Woods v. Kijakazi held that the revised regulations supersede those rules; Martin v. Commissioner Social Security Administration and Gibson v. Kijakazi applied the change.
More on how this was screened

The 3 confirmed treatments are listed below. Courts continue to apply Garrison's rules on symptom testimony and when to award benefits. All 226 flagged citations have been read.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

226 later cases cite Karen Garrison v. Carolyn W. Colvin; 226 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Karen Garrison v. Carolyn W. Colvin?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Superseded by statute or rule

  • The Ninth Circuit held that the 2017 Social Security regulations displaced the former medical opinion hierarchy and the specific and legitimate reasons standard for later-filed claims.

    Woods v. Kijakazi · Ninth Circuit · filed

    As a threshold matter, we must decide whether recent changes to the Social Security Administration’s regulations displace our longstanding case law requiring an ALJ to provide “specific and legitimate” reasons for rejecting an examining doctor’s opinion. We conclude that they do. For claims subject to the new regulations, the former hierarchy of medical opinions—in which we assign presumptive weight based on the extent of the doctor’s relationship with the claimant—no longer applies.
    Read the full opinion on CourtListener →

  • The district court applied the revised regulations and rejected Garrison's former specific and legitimate reasons requirement for medical source opinions.

    Martin v. Commissioner Social Security Administration · District of Oregon · filed

    Garrison, 759 F.3d at 1012 (explaining that, under the old regulations, and ALJ “may only reject [the opinion of a treating or examining doctor] by providing specific and legitimate reasons that are supported by substantial evidence”). ... Consequently, the ALJ did not need to give a “specific and legitimate” reason to discredit the medical source evidence.
    Read the full opinion on CourtListener →

  • The district court recognized that Garrison was decided under law since superseded by the revised regulations.

    Gibson v. Kijakazi · Eastern District of Washington · filed

    However, Garrison was decided under law that has since been superseded.
    Read the full opinion on CourtListener →

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