Civitts v. Commissioner of Social Security

CourtDistrict Court, M.D. Tennessee
DecidedMay 21, 2026
Docket3:25-cv-00452
StatusUnknown

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

Bluebook
Civitts v. Commissioner of Social Security, (M.D. Tenn. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

WARNER CIVITTS, ) Plaintiff, ) ) Case No. 3:25-cv-00452 v. ) Magistrate Judge Frensley ) FRANK BISIGNANO, ) COMMISSIONER OF SOCIAL ) SECURITY ADMINISTRATION, ) Defendant. )

MEMORANDUM OPINION This is a civil action filed pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3), to obtain judicial review of the final decision of the Commissioner of Social Security finding Plaintiff was not disabled and denying Plaintiff Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”), as provided under the Social Security Act (“the Act”), as amended. The case is currently pending on Plaintiff’s Motion for Judgment on the Administrative Record. Docket No. 13. Plaintiff has filed an accompanying Memorandum. Docket No. 14. Defendant has filed a Response, arguing the decision of the Commissioner was supported by substantial evidence and should be affirmed. Docket No. 18. Plaintiff has filed a Reply. Docket No. 19. For the reasons stated below, the Plaintiff’s Motion for Judgment on the Administrative Record (Docket No. 13) is DENIED, and the decision of the Commissioner is AFFIRMED. I. INTRODUCTION Plaintiff filed his application for SSI and protectively filed his application for DIB on February 5, 2021, alleging he had been disabled since February 1, 2019, due to mental illness, autistic spectrum disorder, mood disorder, ADHD, learning and social deficits and disabilities,

1 visual, motor, and processing speed delays, high blood pressure, bipolar disorder, Asperger’s disorder, and an I.Q. score of 86. Docket No. 12, Attachment (“TR”), TR 224-30, 244. Plaintiff’s applications were denied both initially (TR 111, 129-30) and upon reconsideration (TR 131-32, 167-68). Plaintiff subsequently requested (TR 196-97) and received (TR 47-91) a hearing.

Plaintiff’s hearing was conducted on November 28, 2023, by Administrative Law Judge (“ALJ”) Renee Andrews-Turner. TR 47. Plaintiff, Plaintiff’s mother Lynn Civitts, and vocational expert (“VE”), JoAnn Bullard, appeared and testified. Id. On March 26, 2024, the ALJ issued a decision unfavorable to Plaintiff, finding Plaintiff was not disabled within the meaning of the Act and Regulations. TR 25-46. Specifically, the ALJ made the following findings of fact: 1. The claimant meets the insured status requirements of the Social Security Act through December 31, 2024.

2. The claimant engaged in substantial gainful activity during the following periods (20 CFR 404.1520(b), 404.1571 et seq., 416.920(b) and 416.971 et seq.).

3. However, there has been a continuous 12-month period(s) during which the claimant did not engage in substantial gainful activity i.e., February 1, 2019, through December 2020. The undersigned will also address current evidence secondary to a reduction in hours as noted on the claimant’s mother [sic] statement (Ex. 14E). The remaining findings address the period(s) the claimant did not engage in substantial gainful activity.

4. The claimant has the following severe impairments: mild autism disorder and bipolar disorder (20 CFR 404.1520(c) and 416.920(c)).

5. The claimant does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 404.1525, 404.1526, 416.920(d), 416.925 and 416.926).

6. After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform a full range of work at all exertional levels but with the following nonexertional

2 limitations: that the claimant can understand, remember and carry out simple instructions; can maintain concentration, pace and persistence for 2 hours at a time during in [sic] an 8-hour workday for simple instructions; can occasionally interact with the public, coworkers and supervisors; and adapt to occasional changes in the workplace.

7. The claimant is unable to perform any past relevant work (20 CFR 404.1565 and 416.965).

8. The claimant was born on February 4, 1997, and was 21 years old, which is defined as a younger individual age 18-49, on the alleged disability onset date (20 CFR 404.1563 and 416.963).

9. The claimant has at least a high school education (20 CFR 404.1564 and 416.964).

10. Transferability of job skills is not material to the determination of disability because using the Medical-Vocational Rules as a framework supports a finding that the claimant is “not disabled,” whether or not the claimant has transferable job skills (See SSR 82-41 and 20 CFR Part 404, Subpart P, Appendix 2).

11. Considering the claimant’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that the claimant can perform (20 CFR 404.1569, 404.1569a, 416.969, and 416.969a).

12. The claimant has not been under a disability, as defined in the Social Security Act, from February 1, 2019, through the date of this decision (20 CFR 404.1520(g) and 416.920(g)).

TR 31-34, 41-42. On February 20, 2025, the Appeals Council issued a letter declining to review the case (TR 2-8), thereby rendering the decision of the ALJ the final decision of the Commissioner. This civil action was thereafter timely filed, and this Court has jurisdiction. 42 U.S.C. § 405(g). If the Commissioner’s findings are supported by substantial evidence, based upon the record as a whole, then these findings are conclusive. Id.

3 II. REVIEW OF THE RECORD The parties and the ALJ have thoroughly summarized and discussed the medical and testimonial evidence of record. Accordingly, the Court will discuss those matters only to the extent necessary to analyze the parties’ arguments.

III. CONCLUSIONS OF LAW A. Standards of Review This Court’s review of the Commissioner’s decision is limited to the record made in the administrative hearing process. Jones v. Sec’y of Health & Human Servs., 945 F. 2d 1365, 1369 (6th Cir. 1991). The purpose of this review is to determine: (1) whether substantial evidence exists in the record to support the Commissioner’s decision, and (2) whether any legal errors were committed in the process of reaching that decision. Id. “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.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (alteration in original), quoting Consol.

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Civitts v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/civitts-v-commissioner-of-social-security-tnmd-2026.