Bringham v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Oklahoma
DecidedJuly 29, 2025
Docket5:24-cv-01046
StatusUnknown

This text of Bringham v. Commissioner of Social Security Administration (Bringham v. Commissioner of Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bringham v. Commissioner of Social Security Administration, (W.D. Okla. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF OKLAHOMA BRON B., ) ) Plaintiff, ) ) v. ) Case No. CIV-24-1046-R ) FRANK BISIGNANO,1 ) Commissioner, ) Social Security Administration, ) ) Defendant. ) REPORT AND RECOMMENDATION Plaintiff Bron B. seeks judicial review of the denial by the Social Security Administration (“SSA”) of his application for supplemental security income. United States District Judge David L. Russell referred this matter to the undersigned Magistrate Judge for proposed findings and recommendations consistent with 28 U.S.C. §§ 636(b)(1)(B) and 636(b)(3), and Federal Rule of Civil Procedure 72(b). The Commissioner has filed the administrative record (“AR”), Doc. 6, and both parties have briefed their positions, Docs. 9, 17, 18.2 For the following reasons, the undersigned recommends that the Court reverse and remand the Commissioner’s decision for further administrative proceedings.

1 Frank Bisignano is substituted as the proper party defendant pursuant to Federal Rule of Civil Procedure 25(d). 2 Citations to the parties’ briefs reference the Court’s ECF pagination. Citations to the AR reference the document’s original pagination. I. Procedural Background Initially and on reconsideration, the SSA denied Plaintiff’s application for benefits. On September 20, 2022, an administrative law judge (“ALJ”) issued a decision finding that

Plaintiff was not disabled within the meaning of the Social Security Act. AR 17-23. The Appeals Council denied Plaintiff’s request for review. AR 1-6. Thereafter, Plaintiff appealed to this Court, which reversed the Commissioner’s decision and remanded for further administrative proceedings. AR 641-42. Pursuant to that order, the Appeals Council remanded the case to a different ALJ for further proceedings and a new decision.

AR 644-50. On August 2, 2024, a second ALJ issued a decision finding that Plaintiff was not disabled within the meaning of the Social Security Act. AR 578-97. As Plaintiff did not file exceptions to the hearing decision, the Appeals Council did not assume jurisdiction and the ALJ’s decision became the Commissioner’s final decision. See 20 C.F.R.

§ 416.1484(d). II. The ALJ’s Decision The ALJ followed the five-step sequential evaluation process required by agency regulations. See Wall v. Astrue, 561 F.3d 1048, 1052 (10th Cir. 2009) (explaining the five- step process); see also 20 C.F.R. § 416.920 (same). The ALJ first determined that Plaintiff had not engaged in substantial gainful activity since the application date. AR 581. At step

two, the ALJ determined that Plaintiff had the severe impairments of degenerative disc disease of the lumbar spine, to include osteomyelitis, discitis, and Pott disease. Id. At step three, the ALJ found Plaintiff’s impairments do not meet or medically equal any of the impairments listed at 20 C.F.R. Part 404, Subpart P, App. 1. Id. At step four, the ALJ found that Plaintiff had the residual functional capacity

(“RFC”) to perform work at the light exertional level, as defined in 20 C.F.R. § 416.967(b), with additional exertional and nonexertional limitations. AR 581-88. The ALJ then found that Plaintiff is unable to perform any past relevant work. AR 588-89. Relying at the final step on the vocational expert’s testimony, the ALJ found Plaintiff can perform other work existing in significant numbers in the national economy.

AR 589-90. Therefore, the ALJ concluded that Plaintiff has not been under a disability, for purposes of the Social Security Act, since the application date. AR 590. III. Standard of Review Judicial review of the Commissioner’s final decision is limited to determining whether the factual findings are supported by substantial evidence in the record and

whether the correct legal standards were applied. Noreja v. Comm’r, SSA, 952 F.3d 1172, 1177 (10th Cir. 2020). Under such review, “common sense, not technical perfection, is [the Court’s] guide.” Keyes-Zachary v. Astrue, 695 F.3d 1156, 1167 (10th Cir. 2012). In reviewing the agency’s factual findings, the Court will “neither reweigh the evidence nor substitute [its] judgment for that of the agency.” Vigil v. Colvin, 805 F.3d 1199, 1201 (10th Cir. 2015) (citation modified). Instead, the Court “looks to an existing

administrative record and asks whether it contains sufficient evidence to support the agency’s factual determinations.” Biestek v. Berryhill, 587 U.S. 97, 102 (2019) (citation modified). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. at 103 (citation modified). “It requires more than a scintilla, but less than a preponderance.” Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). “Evidence is not substantial if it is overwhelmed by other evidence in the

record or constitutes mere conclusion.” Noreja, 952 F.3d at 1178 (citation modified). In addition to a lack of substantial evidence, “the agency’s failure to apply the correct legal standards, or show [the Court] that it has done so, is also grounds for reversal.” Hamlin v. Barnhart, 365 F.3d 1208, 1214 (10th Cir. 2004). IV. Analysis

On January 5, 2021, Plaintiff had emergency surgery including a T4 to T11 laminectomy and T4 to L1 instrumented posterior spinal fusion. AR 408-10. Plaintiff alleges disability based primarily on back pain, lack of spinal mobility, and resulting functional limitations. AR 262. He claims disability began on January 4, 2021. AR 259. A. Subjective symptom evaluation 1. Appeals Council’s remand instructions In its order of remand, the Appeals Council instructed the second ALJ to reconsider

Plaintiff’s RFC as well as “further evaluate [Plaintiff’s] alleged symptoms, particularly with respect [to] his reported inability to stand, walk, or sit for extended periods, and provide rationale in accordance with the disability regulations pertaining to evaluation of symptoms.” AR 647 (citation modified). In discussing the first ALJ’s decision, the Appeals Council observed that Plaintiff “has repeatedly alleged in function reports, and

testified extensively to, an inability to stand, walk, or sit for more than 20-25 minutes at a time,” while the “only evidence that the claimant could stand and/or walk for 6 hours a day came from the state agency medical consultants.” AR 646 (citing AR 20; 43-45; 46-48; 273; 282; 300; 310; 318; 322; 325). The Appeals Council also discussed certain medical records the first ALJ relied on, but found such reliance unwarranted as the records did “not

contradict the claimant’s reported difficulty standing, walking, or sitting for extended periods.” AR 646-47. The Appeals Council instructed that on remand “further consideration of the claimant’s reported symptoms is required.” AR 647. The second ALJ did not adequately follow those instructions.

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Related

Watkins v. Barnhart
350 F.3d 1297 (Tenth Circuit, 2003)
Hamlin v. Barnhart
365 F.3d 1208 (Tenth Circuit, 2004)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Wall v. Astrue
561 F.3d 1048 (Tenth Circuit, 2009)
Sitsler v. Astrue
410 F. App'x 112 (Tenth Circuit, 2011)
Luna v. Bowen
834 F.2d 161 (Tenth Circuit, 1987)
Dennis Wayne Moore v. United States
950 F.2d 656 (Tenth Circuit, 1991)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Wilson v. Astrue
602 F.3d 1136 (Tenth Circuit, 2010)
Vigil v. Colvin
805 F.3d 1199 (Tenth Circuit, 2015)
Brownrigg v. Berryhill
688 F. App'x 542 (Tenth Circuit, 2017)

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Bluebook (online)
Bringham v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bringham-v-commissioner-of-social-security-administration-okwd-2025.