CHAU v. BISIGNANO

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 18, 2025
Docket2:24-cv-03092
StatusUnknown

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

Bluebook
CHAU v. BISIGNANO, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

KHANG A. C.,1 : Plaintiff, : CIVIL ACTION v. : No. 24-3092 : FRANK BISIGNANO, : Commissioner of Social Security, : Defendant. :

MEMORANDUM OPINION

HON. JOSÉ RAÚL ARTEAGA August 18, 2025 United States Magistrate Judge2

The Commissioner of Social Security, through an Administrative Law Judge (“ALJ”), determined that Plaintiff Khang A. C. was not disabled and denied his claim for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381–1383. Khang A. C. seeks review of the decision pursuant to 42 U.S.C. § 405(g), arguing that substantial evidence does not support the ALJ’s decision because the ALJ erred by (1) rejecting the examining psychologists’ opinions; and (2) omitting certain

1 Khang A. C. is referred to solely by his first name and initials in accordance with this Court’s standing order. See Standing Order, In re: Party Identification in Social Security Cases (E.D. Pa. June 10, 2024), https://www.paed.uscourts.gov/sites/paed/files/documents/locrules/standord/SO_ pty-id-ss.pdf (last visited August 13, 2025).

2 The parties have consented to the jurisdiction of a United States Magistrate Judge to conduct all proceedings, including the entry of a final judgment, pursuant to 28 U.S.C. § 636(c). (See ECF 4.) limitations from the hypothetical to the Vocational Expert (“VE”). (See ECF 8 at ECF p. 5, 18.) In response, the Commissioner argues that ALJ properly weighed the medical

opinion evidence and substantial evidence supports the ALJ’s finding. (See ECF 11 at ECF p. 4.) After careful review of the entire record, Khang A. C.’s request for review is DENIED and the Commissioner’s decision is AFFIRMED. I. BACKGROUND On March 31, 2015, Khang A. C. filed an application for SSI under Title XVI of the

Social Security Act. (ECF 5-3 at ECF p. 11.) He alleged disability due to autism since January 4, 1994. (Id. at ECF p. 3.) The Social Security Administration denied his application in August 2015. (ECF 5-4 at ECF p. 6-10.) In October 2017, Khang A. C. requested a hearing. (Id. at 11.) Hearings were held in October 2017 and February 2018. (ECF 5-2 at ECF p. 235-45, 181-234.) In June 2018, an ALJ found that he was not disabled

from March 31, 2015 (his application date) through the date of decision and denied his claim for SSI. (ECF 5-3 at ECF p. 12-28.) The next month, Khang A. C. requested Appeals Council review. (ECF 5-4 at ECF p. 107.) The Appeals Council granted his request, vacated the hearing decision, and remanded the case to an ALJ in June 2019. (ECF 5-3 at ECF p. 35-37.)

A third hearing was held in October 2019. (ECF 5-2 at ECF p. 129-80.) That December, the ALJ again found that Khang A. C. was not disabled from March 31, 2015, through the date of the decision, and denied an award of benefits. (Id. at 103-23.) Khang A. C. requested review of the decision in January 2020 (ECF 5-4 at ECF p. 169-71), which the Appeals Council denied in March 2021, affirming the ALJ’s decision as the Commissioner’s “final decision.” (ECF 5-2 at ECF p. 2.)

Following the denial of review, Khang A. C. filed a previous appeal to this Court. (See E.D. Pa. Civ. A. No. 21-2404.) In February 2022, the Court remanded his case for a new hearing on the Commissioner’ motion, (ECF 5-9 at ECF p. 2), and the Appeals Council issued an order of remand in August 2022. (Id. at ECF p. 11-16.) In February 2024, Khang A. C. amended his claim to seek a closed period of disability from his date of application through December 31, 2020, acknowledging that, “[a]fter that date he

began working above” the substantial gainful activity threshold. (ECF 5-12 at ECF p. 11.) A fourth hearing was held in March 2024. (ECF 5-8 at ECF p. 32-56.) An ALJ issued another denial in May 2024, determining that the record established “some limitations in functioning but not to the degree alleged” and that Khang A. C. “is capable of performing past relevant work” that is not precluded by his residual functional

capacity (“RFC”). (Id. at ECF p. 13, 20.) According to the ALJ, Khang A. C. had the RFC “to perform a full range of work at all exertional levels” but subject to non-exertional limitations: “he can apply commonsense understanding to carry out detailed but uninvolved written or oral instructions and deal with problems involving a few concrete variables on or from standardized situations, but he cannot perform tasks with a

production rate requirement” and he “can occasionally interact with supervisors, coworkers, and the public,” and, in a routine work setting, he can “tolerate occasional changes . . . .” (Id. at ECF p. 11.) So, with the ability to perform “past relevant work as a dishwasher, a busser, and a silver wrapper,” the ALJ found that Khang A.C. was not disabled since March 31, 2015. (Id. at ECF p. 20, 22.) Because the Appeals Council did not review this decision, it became the Commissioner’s final decision by operation of law

on July 9, 2024. (Id. at ECF p. 3.) Khang A.C. filed this action on July 16, 2024. (ECF 1.) He seeks judgment in his favor and an award of benefits or remand to the Commissioner again. (ECF 8 at ECF p. 1.) II. LEGAL STANDARDS The limited question before the Court on review of the Commissioner’s final determination is not whether Khang A. C. was disabled. Rather, the Court must

determine whether substantial evidence supports the Commissioner’s finding that he was not, and whether the Commissioner, through the ALJ, correctly applied the relevant law. See 42 U.S.C. § 405(g). Any legal issues decided by the ALJ are subject to “plenary review.” Johnson v. Comm’r of Soc. Sec., 529 F.3d 198, 200 (3d Cir. 2008). Courts review the Commissioner’s factual findings to see if “substantial evidence” exists to support

them by looking at the existing administrative record. Biestek v. Berryhill, 587 U.S. 97, 102 (2019). “[T]he threshold for such evidentiary sufficiency is not high . . . .” Id. at 103. Substantial evidence “means—and means only—’such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Brown v. Kijakazi, No. 20-6181, 2021 WL 5356802, at *5 (E.D. Pa Nov. 17, 2021) (quoting Consolidated Edison Co. v. NLRB,

305 U.S. 197, 229 (1938)). It does not “mean a large or considerable amount of evidence.” Pierce v. Underwood, 487 U.S. 552, 565 (1988). When substantial evidence supports the ALJ’s decision, then the ALJ’s findings of fact “shall be conclusive.” Richardson v. Perales, 402 U.S. 389, 390 (1971) (quoting 42 U.S.C. § 405(g)). This is the case even if the Court “would have decided the factual inquiry differently.” Fargnoli v. Massanari, 247 F.3d 34, 38 (3d Cir. 2001) (citation omitted). Courts

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CHAU v. BISIGNANO, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chau-v-bisignano-paed-2025.