Christopher Cottingham v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 9, 2026
Docket1:24-cv-02130
StatusUnknown

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

Bluebook
Christopher Cottingham v. Frank Bisignano, Commissioner of Social Security, (M.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

CHRISTOPHER COTTINGHAM, : CIVIL NO.: 1:24-cv-02130 : Plaintiff, : (Magistrate Judge Schwab) : v. : : : FRANK BISIGNANO,1 : Commissioner of Social Security, : : Defendant. :

MEMORANDUM OPINION I. Introduction. In this social security action, Plaintiff Christopher Cottingham seeks judicial review of the final decision of the Commissioner of Social Security (“Commissioner”) denying his claims for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. We have jurisdiction under 42 U.S.C. §§ 405(g) and 1383(c)(3). For the reasons

1 Frank Bisignano is now the Commissioner of Social Security, and he is automatically substituted as the defendant in this action. See Fed. R. Civ. P. 25(d) (providing that when a public officer sued in his or her official capacity ceases to hold office while the action is pending, “[t]he officer’s successor is automatically substituted as a party”); 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.”). set forth below, we will vacate the Commissioner’s decision and remand the case to the Commissioner for further proceedings.

II. Background and Procedural History. We refer to the transcript provided by the Commissioner. See docs. 7, 7-1, 7- 2.2 In October 2018, Cottingham filed an application for disability insurance benefits and an application for supplemental security income, alleging that he has

been disabled since July 1, 2018. See Admin. Tr. at 123–131. After the Commissioner administratively denied his claims, id. at 132–35, 160–64, Cottingham requested an administrative hearing, id. at 169–171. On January 28, 2020, Cottingham—who was represented by counsel—as well as a vocational

expert testified at a hearing before Administrative Law Judge Scott Staller (the “ALJ”). Id. at 74–93. On February 28, 2020, the ALJ denied Cottingham’s claims for benefits. Id. at 107-21.

Cottingham appealed the ALJ’s decision to the Appeals Council, which granted his request for review, vacated the ALJ’s decision, and remanded the case to the ALJ. Id. at 147–54. The Appeals Council remanded the case to the ALJ for the ALJ to take the following actions and resolve the following issues: (1) obtain a

2 Because the facts of this case are well known to the parties, we do not repeat them here in detail. Instead, we recite only those facts that bear on Cottingham’s claims. complete copy of an exhibit that was missing hundreds of pages; (2) address the statement of Cottingham’s mother; (3) “[o]btain additional evidence concerning

[Cottingham]’s impairments in order to complete the administrative record in accordance with the regulatory standards regarding consultative examinations and existing medical evidence”; (4) “[f]urther evaluate [Cottingham]’s alleged

symptoms and provide [a] rationale in accordance with the disability regulations pertaining to evaluation of symptoms”; and (5) further consider Cottingham’s “maximum residual functional capacity and provide appropriate rationale with specific references to evidence of record in support of the assessed limitations.” Id.

at 150–51 (citations omitted). After remand, on July 10, 2023, Cottingham appeared with counsel at another hearing before the ALJ. Id. at 49–73. Cottingham testified at the hearing

as did a vocational expert. Id. On April 3, 2024, the ALJ conducted a third hearing. Id. at 33–48. Cottingham, who was represented by counsel, was present as was a vocational expert, but neither of them testified. Id. Rather, only a medical expert—Dr. Krishnan—testified. Id.

On April 23, 2024, the ALJ denied Cottingham’s claims for benefits. Id. at 9–32. Cottingham appealed the ALJ’s decision to the Appeals Council, which denied his request for review. Id. at 1–6. This makes the ALJ’s decision the final

decision of the Commissioner subject to judicial review by this Court. In December 2024, Cottingham, represented by counsel, began this action by filing a complaint seeking review of the Commissioner’s decision denying his

claims. See Doc. 1. He requests that the court reverse the Commissioner’s decision and award him benefits or, in the alternative, remand the case for further proceedings. Id. at 3–4 (Wherefore Clause). He also seeks “such relief” as the

court deems justified, including attorney’s fees. Id. at 4. The parties consented to proceed before a magistrate judge pursuant to 28 U.S.C. § 636(c), and the case was referred to the undersigned. Doc. 5. The Commissioner then filed an answer and a certified transcript of the administrative

proceedings. Docs. 6, 7. The parties filed briefs, see docs. 14, 16, 19, and this matter is ripe for decision.

III. Legal Standards.

A. Substantial Evidence Review—the Role of This Court. When reviewing the Commissioner’s final decision denying a claimant’s application for benefits, “the court has plenary review of all legal issues decided by

the Commissioner.” Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012). But the court’s review of the Commissioner’s factual findings is limited to whether substantial evidence supports those findings. See 42 U.S.C. § 405(g); Biestek v.

Berryhill, 587 U.S. 97, 99 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Biestek, 587 U.S. at 103. Substantial evidence “means— and means only—‘such relevant evidence as a reasonable mind might accept as

adequate to support a conclusion.’” Id. (quoting Consol. Edison Co. of New York v. N.L.R.B., 305 U.S. 197, 229 (1938)). Substantial evidence “is less than a preponderance of the evidence but more

than a mere scintilla.” Jesurum v. Sec’y of U.S. Dep’t of Health & Human Servs., 48 F.3d 114, 117 (3d Cir. 1995). A single piece of evidence is not substantial evidence if the ALJ ignores countervailing evidence or fails to resolve a conflict created by the evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993).

But in an adequately developed factual record, substantial evidence may be “something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s] finding

from being supported by substantial evidence.” Consolo v. Fed. Maritime Comm’n, 383 U.S. 607, 620 (1966). “In determining if the Commissioner’s decision is supported by substantial evidence the court must scrutinize the record as a whole.” Leslie v. Barnhart, 304 F.Supp.2d 623, 627 (M.D. Pa. 2003).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Securities & Exchange Commission v. Chenery Corp.
318 U.S. 80 (Supreme Court, 1943)
Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Shinseki, Secretary of Veterans Affairs v. Sanders
556 U.S. 396 (Supreme Court, 2009)
Brown v. Astrue
649 F.3d 193 (Third Circuit, 2011)
Diaz v. Commissioner of Social Security
577 F.3d 500 (Third Circuit, 2009)
Brownawell v. Commissioner of Social Security
554 F.3d 352 (Third Circuit, 2008)
Johnson v. Commissioner of Social Security
529 F.3d 198 (Third Circuit, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Christopher Cottingham v. Frank Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-cottingham-v-frank-bisignano-commissioner-of-social-security-pamd-2026.