Autumn D. S. v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, N.D. Indiana
DecidedMarch 9, 2026
Docket2:25-cv-00043
StatusUnknown

This text of Autumn D. S. v. Frank Bisignano, Commissioner of Social Security (Autumn D. S. v. Frank Bisignano, Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Autumn D. S. v. Frank Bisignano, Commissioner of Social Security, (N.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA HAMMOND DIVISION

Autumn D. S.1,

Plaintiff,

v. CASE NO. 2:25-CV-43-SJF

FRANK BISIGNANO, COMMISSIONER OF SOCIAL SECURITY2,

Defendant.

OPINION and ORDER Plaintiff Autumn D. S. (“Ms. S”) seeks judicial review of the Social Security Commissioner’s decision denying Ms. S’s application for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act (“Act”). This Court may enter a ruling based on the parties’ consent pursuant to 28 U.S.C. § 636(b)(1)(B) and 42 U.S.C. § 405(g). [DE 8]. For the reasons discussed below, the Court REMANDS the decision of the Commissioner of the Social Security Administration (“SSA”). I. OVERVIEW OF THE CASE Ms. S protectively filed her application for DIB on January 11, 2021, alleging disability beginning January 1, 2021. (Administrative Record3 15; hereinafter “AR”). She was denied initially, on reconsideration, and after a hearing before an administrative

1 To protect privacy interests, and consistent with the recommendation of the Judicial Conference, the Court refers to the plaintiff by first name, middle initial, and last initial only. 2 Frank Bisignano became the Commissioner of Social Security on May 6, 2025. Under Rule 25(d) of the Federal Rules of Civil Procedure, Frank Bisignano is substituted as the defendant in this suit. 3 Administrative record page numbers are noted in the bottom right corner of each page. law judge (“ALJ”). (Id.). The ALJ issued an unfavorable decision on March 29, 2022. (AR 27). Ms. S then requested further review of the ALJ’s decision, and the Appeals Council

denied this request on September 30, 2022. (AR 1). Thus, the ALJ’s decision became the final decision of the Commissioner. Fast v. Barnhart, 397 F.3d 468, 470 (7th Cir. 2005). Ms. S filed suit this in Court on November 29, 2022, under cause number Salat v. Commissioner of Social Security, Case No. 2:22-cv-364-JD-JPK. On August 22, 2023, Ms. S and the Commissioner jointly moved to remand her case her case for further administrative proceedings, which the Court granted on September 5, 2023. [DE 21, DE

22 in 2:22-cv-364-JD-JPK]. On remand, Ms. S had another hearing before an ALJ on September 10, 2024. Her application was denied in a subsequent decision entered on September 27, 2024. (AR 539). The ALJ’s decision was considered the final decision for judicial review, prompting Ms. S to file the above-captioned case in this Court on January 27, 2025. Thus, this Court has jurisdiction under 42 U.S.C. § 405(g).

II. APPLICABLE STANDARDS A. Disability Standard To qualify for DIB and SSI, a claimant must be “disabled” as defined under the Act. A person is disabled under the Act if “he or she has an inability to engage in any substantial gainful activity by reason of a medically determinable physical or mental

impairment which can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. § 423(d)(1)(A). Substantial gainful activity is defined as work activity that involves significant physical or mental activities done for pay or profit. 20 C.F.R § 404.1572. The Commissioner’s five-step sequential inquiry in evaluating claims for DIB under the Act includes determinations of: (1) whether the claimant is engaged in

substantial gainful activity; (2) whether the claimant’s impairments are severe; (3) whether any of the claimant’s impairments alone or in combination, meet or equal one of the Listings in Appendix 1 to Subpart P of Part 404; (4) whether the claimant can perform his past relevant work based on his Residual Functional Capacity (“RFC”); and, if not, (5) whether the claimant is able to perform other work. 20 C.F.R. §§ 404.1520. The claimant bears the burden of proof at every step except Step Five, where the burden

of proof shifts to the Commissioner. Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir. 2000), as amended (Dec. 13, 2000). B. Standard of Review The Court has authority to review a disability decision by the Commissioner pursuant to 42 U.S.C. § 405(g). But this Court’s role in reviewing social security cases is

limited. Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008). The question on judicial review is not whether the claimant is disabled; the Court considers whether the ALJ used “the correct legal standards and [whether] the decision is supported by substantial evidence.” Roddy v. Astrue, 705 F.3d 631, 636 (7th Cir. 2014) (citing Simila v. Astrue, 573 F.3d 503, 513 (7th Cir. 2009)). Substantial evidence must be “more than a scintilla but

may be less than a preponderance.” Skinner v. Astrue, 478 F.3d 836, 841 (7th Cir. 2007). Substantial evidence has also been understood as “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971); see Summers v. Berryhill, 864 F.3d 523, 526 (7th Cir. 2017). The Supreme Court has also noted that “substantial evidence” is a term of art in administrative law, and that “whatever the meaning of ‘substantial’ in other contexts,

the threshold for such evidentiary sufficiency is not high” in social security appeals. Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). The Court reviews the entire administrative record to determine whether substantial evidence exists, but it may not reconsider facts, reweigh the evidence, resolve conflicts of evidence, decide questions of credibility, or substitute its judgment for that of the ALJ. Young v. Barnhart, 362 F.3d 995, 1001 (7th Cir. 2004).

On the other hand, an ALJ’s decision cannot stand if it lacks evidentiary support or inadequately discusses the issues. Lopez v. Barnhart, 336 F.3d 535, 539 (7th Cir. 2003). At a minimum, the ALJ must articulate her analysis of the record to allow the reviewing court to trace the path of her reasoning and to be assured the ALJ has considered the important evidence in the record. Scott v. Barnhart, 297 F.3d 589, 595 (7th Cir. 2002). The

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Autumn D. S. v. Frank Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/autumn-d-s-v-frank-bisignano-commissioner-of-social-security-innd-2026.