Christie Latonya Ellis v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, S.D. Alabama
DecidedMarch 26, 2026
Docket1:24-cv-00426
StatusUnknown

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

Bluebook
Christie Latonya Ellis v. Frank Bisignano, Commissioner of Social Security, (S.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION CHRISTIE LATONYA ELLIS, ) Plaintiff, ) ) v. ) CIVIL ACTION NO. 1:24-00426-N ) FRANK BISIGNANO, ) Commissioner of Social Security, 1 ) Defendant. )

MEMORANDUM OPINION AND ORDER

Plaintiff Christie Latonya Ellis brought this action under 42 U.S.C. § 405(g) seeking judicial review of a final decision of the Defendant Commissioner of Social Security denying her application for a period of disability and disability

1 Former Commissioner Martin O’Malley resigned effective November 29, 2024, leading to a series of acting Commissioners. Frank Bisignano’s nomination to be Commissioner of Social Security was confirmed on May 6, 2025, and he began his term of service the following day. See:

• https://federalnewsnetwork.com/people/2024/11/omalley-stepping-down- as-ssa-commissioner/ (last visited 3/26/2026)

• https://www.congress.gov/nomination/119th-congress/20 (last visited 3/26/2026)

• https://www.ssa.gov/history/commissioners.html (last visited 3/26/2026)

Accordingly, Bisignano was automatically substituted for former Commissioner O’Malley as the party defendant in this action under Federal Rule of Civil Procedure 25(d), and this change does not affect the pendency of this action. See 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). The Clerk of Court is DIRECTED to update the title of this case on the docket accordingly. insurance benefits (collectively, “DIB”) under Title II of the Social Security Act, 42 U.S.C. § 401, et seq.2 Upon due consideration of the parties’ briefs (Docs# 13,

14) and those portions of the certified transcript of the administrative record (Doc# 12) relevant to the issues raised, the Court finds that the Commissioner’s final decision is due to be REVERSED and REMANDED for further administrative proceedings.3 I. Procedural Background

Ellis protectively filed the subject DIB application with the Social Security Administration (“SSA”) on July 20, 2021. After the application was denied initially, and again on reconsideration, Ellis requested a hearing on her application with an Administrative Law Judge (“ALJ”) of the SSA’s Office of Hearings Operations, which was held on December 6, 2023. On January 10,

2024, the ALJ issued an unfavorable decision on Ellis’s application, finding her not entitled to benefits. (See Doc# 12-2, PageID.49-66). The Commissioner’s decision on Ellis’s application became final when the

2 “Title II of the Social Security Act (Act), 49 Stat. 620, as amended, provides for the payment of insurance benefits to persons who have contributed to the program and who suffer from a physical or mental disability.” Bowen v. Yuckert, 482 U.S. 137, 140, 107 S. Ct. 2287, 96 L. Ed. 2d 119 (1987) (citing 42 U.S.C. § 423(a)(1)(D) (1982 ed., Supp. III)).

3 With the consent of the parties, the Court has designated the undersigned Magistrate Judge to conduct all proceedings and order the entry of judgment in this civil action, in accordance with 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and S.D. Ala. GenLR 73. (See Docs# 10, 11). With the Court’s agreement, the parties waived the opportunity to present o ral argument. (See Docs# 16, 17). Appeals Council with the SSA’s Office of Appellate Operations denied her request for review of the ALJ’s unfavorable decision on October 22, 2024. (See

id., PageID.39-44). Ellis subsequently brought this action under § 405(g) for judicial review of the Commissioner’s final decision. See 42 U.S.C. § 405(g) (“Any individual, after any final decision of the Commissioner of Social Security made after a hearing to which he was a party, irrespective of the amount in controversy, may obtain a review of such decision by a civil action commenced

within sixty days after the mailing to him of notice of such decision or within such further time as the Commissioner of Social Security may allow.”); Ingram v. Comm'r of Soc. Sec. Admin., 496 F.3d 1253, 1262 (11th Cir. 2007) (“The settled law of this Circuit is that a court may review, under sentence four of section 405(g), a denial of review by the Appeals Council.”).

II. Standards of Review “In Social Security appeals, [the Court] must determine whether the Commissioner’s decision is supported by substantial evidence and based on proper legal standards.” Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (quotation omitted).

The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. [293], [301], 135 S. Ct. 808, 815, 190 L. Ed. 2d 679 (2015). Under the substantial- evidence standard, a court looks to an existing administrative record and asks whether it contains “sufficien[t] evidence” to support the agency’s factual determinations. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L. Ed. 126 (1938) (emphasis deleted). And whatever the meaning of “substantial” in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence … is “more than a mere scintilla.” Ibid.; see, e.g., [Richardson v.] Perales, 402 U.S. [389,] 401, 91 S. Ct. 1420[, 28 L. Ed. 2d 842 (1971)] (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L. Ed. 2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly-erroneous standard). Biestek v. Berryhill, 587 U.S. 97, 102-03, 139 S. Ct. 1148, 203 L. Ed. 2d 504 (2019). In reviewing the Commissioner’s factual findings, a court “‘may not decide the facts anew, reweigh the evidence, or substitute our judgment for that of the [Commissioner].’ ” Winschel, 631 F.3d at 1178 (quoting Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004) (alteration in original) (quoting Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983))). “‘Even if the evidence preponderates against the [Commissioner]’s factual findings, [the Court] must affirm if the decision reached is supported by substantial evidence.’” Ingram v. Comm'r of Soc. Sec. Admin., 496 F.3d 1253, 1260 (11th Cir. 2007) (quoting Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990)).

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Christie Latonya Ellis v. Frank Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christie-latonya-ellis-v-frank-bisignano-commissioner-of-social-security-alsd-2026.