Aleshia Harris, on behalf of M.I.D.H., a minor v. Frank J. Bisignano, Commissioner of Social Security

District Court, E.D. Virginia·Decided June 24, 2026·No. 1:24-cv-00933·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

ALESHIA HARRIS, on behalf of ) M.I.D.H., a minor, ) ) Plaintiff, ) ) v. ) Case No. 1:24-cv-00933 (RDA/WBP) ) FRANK J. BISIGNANO, Commissioner of ) Social Security,1 ) ) Defendant. )

PROPOSED FINDINGS OF FACT AND RECOMMENDATIONS In this Social Security appeal, the parties have filed cross-motions for summary judgment. (ECF Nos. 11, 15.) Under 42 U.S.C. § 405(g), Aleshia Harris (“Plaintiff”) seeks judicial review of a final decision of Martin O’Malley, the then-Commissioner of the Social Security Administration (“Commissioner”), denying her claim for Supplemental Security Income (“SSI”) under the Social Security Act. (ECF No. 1.) The Commissioner’s final decision rests on findings by an Administrative Law Judge (“ALJ”) (Administrative Record (“AR”) 7–36) and the Appeals Council for the Office of Appellate Operations (“Appeals Council”) (AR 1–6). The ALJ found that Plaintiff’s minor child, M.I.D.H., was not disabled as defined by the Social Security Act and its applicable regulations, and the Appeals Council denied Plaintiff’s request to review the ALJ’s decision. (AR 1, 25.)

1 Plaintiff filed this action against Martin O’Malley, then Acting Commissioner of Social Security. Under Rule 25(d) of the Federal Rules of Civil Procedure, Commissioner Frank J. Bisignano should be substituted for Mr. O’Malley as the defendant here. No further action needs to be taken to continue this matter because “any action instituted in accordance with . . . subsection [405(g)] shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.” See 42 U.S.C. § 405(g). Under 28 U.S.C. § 636(b)(1)(C), I recommend that the district judge vacate the ALJ’s January 9, 2024, final decision and remand the case for further consideration consistent with these Proposed Findings of Fact and Recommendations. I. STANDARD OF REVIEW AND LEGAL BACKGROUND

Under the Social Security Act, a district court must affirm the Commissioner’s final decision “when an ALJ has applied correct legal standards and the ALJ’s factual findings are supported by substantial evidence.” Mascio v. Colvin, 780 F.3d 632, 634 (4th Cir. 2015) (quoting Bird v. Comm’r of Soc. Sec. Admin., 699 F.3d 337, 340 (4th Cir. 2012)). The term “substantial evidence” means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Easterbrook v. Kijakazi, 88 F.4th 502, 511 (4th Cir. 2023) (citing Shelley C. v. Comm’r of Soc. Sec. Admin., 61 F.4th 341, 353 (4th Cir. 2023) and quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). It is “more than a mere scintilla of evidence but may be somewhat less than a preponderance.” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966)) (internal quotation marks

omitted). “A necessary predicate to engaging in substantial evidence review is a record of the basis for the ALJ’s ruling.” Radford v. Colvin, 734 F.3d 288, 295 (4th Cir. 2013). The decision should include a discussion of which evidence the ALJ found credible and why. Id. (citing Hines v. Bowen, 872 F.2d 56, 59 (4th Cir. 1989)). While the court reviews the Commissioner’s decision with deference to the factual findings, the court gives no such deference to its legal conclusions. Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253, 1260 (11th Cir. 2007) (citations omitted). The court must reverse when the Commissioner fails to apply the correct law or to provide sufficient reasoning for the court to verify the legal analysis. See id. at 1260 (citation omitted). The scope of review is thus limited to determining whether the Commissioner’s findings are supported by substantial evidence and whether the correct legal standards were applied. 42 U.S.C. § 405(g); Brown v. Comm’r of Soc. Sec. Admin., 873 F.3d 251, 267 (4th Cir. 2017) (citations omitted). II. APPLICABLE LAW AND THE THREE-STEP SEQUENTIAL EVALUATION FOR CHILDREN

To be entitled to benefits, a child claimant must be disabled, meaning the child must have a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and which can be expected to result in death or that has lasted or can be expected to last for a continuous period of at least twelve months. See 42 U.S.C. § 1382c(a)(3)(C)(i). A qualifying “physical or mental impairment” is one that results from anatomical, physiological, or psychological abnormalities that can be shown by medically acceptable clinical and laboratory diagnostic techniques. 42 U.S.C. §§ 423(d)(3) (SSDI), 1382c(a)(3)(D) (SSI). The Social Security Administration’s (“SSA”) regulations establish a three-step “sequential evaluation process” to determine whether a child claimant is disabled. 20 C.F.R. §§ 416.924(b)–(d), (g). Under this process, the ALJ must determine, in sequence, the following: (1) whether the claimant is currently engaged in substantial gainful activity; (2) whether the claimant has a medically determinable impairment or combination of impairments that is severe; and (3) whether the severe impairment or combination of impairments meets, medically equals,

or functionally equals a disability listing in 20 C.F.R. Part 404, Subpart P, Appendix 1. 20 C.F.R. §§ 416.924(a)–(d), 416.925, 416.926a. The claimant bears the burden to prove that the impairment or impairments medically or functionally equal one of the listed impairments. S.R. ex rel. R.R. v. Barnhart, 371 F. Supp. 2d 796, 799 (W.D. Va. 2005). To medically equal a listed impairment, a claimant must establish symptoms, signs and laboratory findings at least equal in severity and duration to each element of the most similar

Free access — add to your briefcase to read the full text and ask questions with AI

Aleshia Harris, on behalf of M.I.D.H., a minor v. Frank J. Bisignano, Commissioner of Social Security, (E.D. Va. 2026).

Aleshia Harris, on behalf of M.I.D.H., a minor v. Frank J. Bisignano, Commissioner of Social Security (Aleshia Harris, on behalf of M.I.D.H., a minor v. Frank J. Bisignano, Commissioner of Social Security) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Calabrese v. Astrue
358 F. App'x 274 (Second Circuit, 2009)
Ingram v. Commissioner of Social Security Administration
496 F.3d 1253 (Eleventh Circuit, 2007)
Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Jimmy Radford v. Carolyn Colvin
734 F.3d 288 (Fourth Circuit, 2013)
Murphy Ex Rel. Murphy v. Astrue
496 F.3d 630 (Seventh Circuit, 2007)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)
Travis Chaney v. Carolyn W. Colvin
812 F.3d 672 (Eighth Circuit, 2016)
George Monroe v. Carolyn Colvin
826 F.3d 176 (Fourth Circuit, 2016)
Brown v. Commissioner Social Security Administration
873 F.3d 251 (Fourth Circuit, 2017)
Nikki Thomas v. Nancy Berryhill
916 F.3d 307 (Fourth Circuit, 2019)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Margaret Shinaberry v. Andrew Saul
952 F.3d 113 (Fourth Circuit, 2020)
Tackett v. Apfel
180 F.3d 1094 (Ninth Circuit, 1999)