Parra

I. Background

On April 15, 1994, Joseph Parra (“Parra”) applied for Dis- ability and Supplemental Security Income benefits under Titles II and XVI of the Social Security Act. Parra alleged dis- ability since November 1, 1992 due to alcoholism and bursi- tis. Following a hearing, an Administrative Law Judge (“ALJ”) denied Parra’s application. The ALJ found that Parra’s testimony regarding his physical ailments was neither credible nor medically supported. He also found that 42 U.S.C. § 423(d)(2)(C) barred Parra from receiving benefits because Parra’s alcoholism was a material contributing factor to his disability. Parra appealed this decision to the district court, which remanded the case to the ALJ under 42 U.S.C. § 405(g) with instructions to consider a medical examination performed upon Parra following the ALJ’s decision.

Parra died on September 8, 2000 from cardiovascular col- lapse, hepatorenal syndrome, hepatocellular carcinoma, and liver cirrhosis. Parra’s daughter, Cathleen, was substituted as 3438 PARRA v. ASTRUE plaintiff and testified at a hearing the following month. Subse- quently, the ALJ issued a decision finding that Parra’s alco- holism was…