Christopher Bonham v. Frank Bisignano

── Christopher Bonham v. Frank Bisignano ── Court: Court of Appeals for the Eighth Circuit Date: June 02, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-2999 ___________________________ Christopher Brad Bonham lllllllllllllllllllllPlaintiff - Appellant v. Frank Bisignano, Commissioner of Social Security lllllllllllllllllllllDefendant - Appellee ____________ Appeal from United States District Court for the Western District of Missouri ____________ Submitted: September 16, 2025 Filed: June 2, 2026 ____________ Before LOKEN, KELLY, and ERICKSON, Circuit Judges. ____________ LOKEN, Circuit Judge. Christopher Bonham is a veteran with a long history of neck and back problems. In May 2012, following his military service, these problems worsened, and he complained to his primary medical care provider at the Department of Veterans Affairs (VA). Medical imaging in July showed cervical spondylosis with a herniated disk at C6-C7, causing neural foraminal stenosis.1 A neurosurgeon performed a comprehensive exam. Based on the medical imaging and severe pain Bonham was experiencing, the neurosurgeon decided surgery was appropriate. Bonham had C6- C7 spinal fusion surgery in October. In 2016, after repeated trips to the emergency room and to various doctors for treatment, Bonham underwent a VA Compensation and Pension physical examination performed by Jon Keller, a physician’s associate (PA), who concluded Bonham was unable to use his left arm.2 The VA granted him limited disability benefits. I. After relying on VA benefits for five years, Bonham applied to the Social Security Administration (SSA) for Social Security disability benefits in 2021, alleging a disability onset date of May 12, 2012. As his insured status expired in 2016, he was eligible for SSA disability benefits from May 12, 2012 to December 31, 2016. He continued to receive VA benefits. Bonham’s disability application alleged several severe impairments, including degenerative disk disease, cervical spondylosis, left ankle pain, hypertension, sinus problems, unspecified depressive disorder and alcohol abuse. In July 2022, SSA 1 Foraminal stenosis occurs when the spinal cord narrows and causes compression of the spinal nerves. Cleveland Clinic, Foraminal Stenosis, https://my.clevelandclinic.org/health/diseases/24856-foraminal-stenosis. 2 PAs generally undergo three years of further education after obtaining their undergraduate degree, with no residency requirement. Am. Acad. of Physician’s Associates: Career Central, Become a PA https://www.aapa.org/career-central/ become-a-pa/. Physicians attend four years of schooling after graduating college and three to seven years of residency and fellowship training. Ass’n of Am. Med. Colls.: Aspiring Docs, MD and DO Programs, https://students-residents.aamc.org/media/ 9971/download. -2- Administrative Law Judge Jan E. Dutton (the ALJ) conducted an informal administrative hearing at which Bonham and a vocational expert (VE) testified. Bonham’s testimony in support of his claim detailed the effects of his impairments during the period for which he is seeking SSA disability benefits, May 12, 2012 to December 31, 2016 -- that he was unable to use his left arm, as he told PA Keller in 2016; is almost bedridden; cannot bend down; and could only lift one two-liter bottle of soda in his left arm. Bonham presented no medical opinion evidence regarding his ability to perform work. Regarding the lack of medi