Bogue v. Bisignano

CourtDistrict Court, E.D. Virginia
DecidedJuly 29, 2025
Docket3:24-cv-00623
StatusUnknown

This text of Bogue v. Bisignano (Bogue v. Bisignano) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bogue v. Bisignano, (E.D. Va. 2025).

Opinion

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

DAVID B.,1 ) ) Plaintiff, ) ) v. ) Civil No. 3:24-cv-623 (REP) ) FRANK BISIGNANO, ) Commissioner of Social Security,2 ) ) Defendant. ) _______________________________________)

REPORT AND RECOMMENDATION In this action, Plaintiff David B. seeks review of the Commissioner of the Social Security Administration’s (“SSA”) decision to deny his Title XVI application for Supplemental Security Income (“SSI”). This matter comes before the Court for a Report and Recommendation under 28 U.S.C. § 636(b)(1)(B) on cross-motions for summary judgment. (ECF Nos. 5, 10, 12.) The motions have been fully briefed (ECF Nos. 10, 12, 13), making this matter ripe for review. Plaintiff requests that the Commissioner’s decision be vacated and remanded for a de novo hearing and new decision. (ECF No. 10, at 10.) As the basis for such relief, Plaintiff argues that the Administrative Law Judge (“ALJ”) failed to properly evaluate the effect of his obesity on his other impairments in determining his residual functional capacity (“RFC”) assessment. (ECF No. 10, at 5-10.) In response, the Commissioner contends that the ALJ articulated how she considered

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that federal courts refer to claimants by their first names and last initials in social security cases. 2 Frank Bisignano was sworn in as the Commissioner of Social Security on May 7, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, he has been substituted for the former Acting Commissioner as Defendant in this action. 42 U.S.C. § 405(g). No further action need be taken. 42 U.S.C. § 405(g). Plaintiff’s obesity throughout her decision and further argues that Plaintiff has not identified any specific evidence demonstrating additional functional limitations related to obesity that the ALJ failed to consider. (ECF No. 12, at 14-19.) For the reasons set forth below, the Court finds that the ALJ applied the correct legal

standard and considered the cumulative effects of obesity and Plaintiff’s other impairments. Because substantial evidence supports the ALJ’s decision, the Court RECOMMENDS that Plaintiff’s Motion for Summary Judgment (ECF No. 10) be DENIED, Defendant’s Motion for Summary Judgment (ECF No. 12) be GRANTED, and the final decision of the Commissioner be AFFIRMED. I. PROCEDURAL HISTORY Plaintiff filed a prior application for SSI on July 1, 2019, alleging disability beginning on March 1, 2016. (Administrative Record (“R.”) at 65.)3 After an administrative hearing, Plaintiff was denied benefits on April 6, 2021. (R. at 62.) He did not appeal. Plaintiff filed another application for SSI on July 15, 2021, alleging disability beginning

on April 7, 2021. (R. at 81.) In his application, Plaintiff alleged that he suffered from depression, back pain, lumbar radiculopathy, coronary artery disease, obesity, hernia, high blood pressure, gastroesophageal reflux disease (“GERD”), hyperlipidemia, sleep apnea, and diabetes. (R. at 82.) The SSA denied Plaintiff’s claim initially and again upon reconsideration. (R. at 81, 102.) Plaintiff requested a hearing before an ALJ, and one was held on October 23, 2023. (R. at 32-61, 127.) At

3 The administrative record in this case remains filed under seal, pursuant to E.D. Va. Loc. R. 5 and 7(C). In accordance with these rules, the Court will exclude personal identifiers from this Report and Recommendation. The Court will further restrict its discussion of Plaintiff’s medical information to the extent necessary to result in a proper analysis of the case. the administrative hearing, the ALJ granted Plaintiff’s oral and written motion to amend the alleged onset date of disability to October 23, 2023. (R. at 38, 237.) On January 9, 2024, the ALJ issued a written decision, finding Plaintiff not disabled under the Social Security Act (“the Act”) since July 15, 2021, the date of Plaintiff’s application. (R. at

19-26.) On July 11, 2024, the SSA Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the final decision of the Commissioner. (R. at 1-3.) Plaintiff now seeks judicial review pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3). II. STANDARD OF REVIEW The Act defines a disability as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death, or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). An individual has a disability “only if his [or her] physical or mental impairment or impairments are of such severity that he [or she] is not only unable to do his [or her] previous work but cannot, considering his [or her] age, education, and

work experience, engage in any other kind of substantial gainful work which exists in the national economy. . . .” Id. § 423(d)(2)(A). SSA regulations set forth a five-step process to determine whether an individual is disabled. 20 C.F.R. § 416.920(a)(4); see Mascio v. Colvin, 780 F.3d 632, 634-35 (4th Cir. 2015) (describing the ALJ’s five-step sequential evaluation). At step one, the ALJ reviews the claimant’s current work activity to determine if he or she has been participating in substantial gainful activity. 20 C.F.R. § 416.920(a)(4)(i). At step two, the ALJ asks whether the claimant’s medical impairments meet the regulations’ severity and duration requirements. Id. § 416.920(a)(4)(ii). At step three, the ALJ determines whether the medical impairments meet or equal an impairment listed in the regulations. Id. § 416.920(a)(4)(iii). Between steps three and four, the ALJ determines the claimant’s RFC, which accounts for the most that the claimant can do despite his or her impairments. Id. § 416.920(a). At step four, the ALJ assesses whether the claimant can perform his or her past employment

given his or her RFC. Id. § 416.920(a)(4)(iv). The burden of proof remains with the claimant through step four of the analysis, and the claimant must prove that his or her limitations preclude the claimant from performing his or her past relevant work. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987); Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012). If such past work can be performed, then benefits will not be awarded, and the analysis ends. See 20 C.F.R. § 416.920(e).

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Bogue v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bogue-v-bisignano-vaed-2025.