Crayton v. Bisignano

CourtDistrict Court, N.D. Illinois
DecidedSeptember 2, 2025
Docket1:25-cv-02146
StatusUnknown

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

Bluebook
Crayton v. Bisignano, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

CYNTHIA C.,1 ) ) Plaintiff, ) ) No. 25 C 2146 v. ) ) Magistrate Judge Gabriel A. Fuentes FRANK BISIGNANO, ) Commissioner of Social Security,2 ) ) Defendant. )

MEMORANDUM OPINION AND ORDER3

Before the Court is Cynthia C.’s motion for summary judgment (D.E. 18), her memorandum requesting the Court reverse and remand the Administrative Law Judge’s (“ALJ”) decision denying her applications for disability insurance benefits (“DIB”) and supplemental security income (“SSI”) (D.E. 19), Defendant’s memorandum in support of his motion for summary judgment to affirm the ALJ’s decision (D.E. 20), and Plaintiff’s reply (D.E. 21). I. Procedural History Plaintiff applied for SSI and DIB on September 23, 2021, alleging a disability onset date of August 1, 2021. (R. 15.) The ALJ held a hearing on August 7, 2023, and issued a written decision on September 13, 2023, denying Plaintiff’s applications and finding her not disabled

1 The Court in this order is referring to Plaintiff by her first name and first initial of her last name in compliance with Internal Operating Procedure No. 22 of this Court. To the extent the Court uses pronouns in this order, the Court uses those pronouns used by the parties in their memoranda.

2 The Court substitutes Frank Bisignano for his immediate predecessor, Leland Dudek, as the proper defendant in this action pursuant to Federal Rule of Civil Procedure 25(d) (a public officer’s successor is automatically substituted as a party).

3 On May 21, 2025, by consent of the parties and pursuant to 28 U.S.C. § 636(c) and Local Rule 73.1, this case was reassigned to this Court for all proceedings, including entry of final judgment. (D.E. 16.) under the Social Security Act (the “Act”) from her alleged onset date of August 1, 2021, through the date of the opinion, September 13, 2023. (R. 15-25.)4 This appeal is of that final decision. II. The ALJ Decision The ALJ applied the Social Security Administration’s (“SSA”) five-step sequential

evaluation process to Plaintiff’s claim. At Step One, the ALJ found Plaintiff had not engaged in substantial gainful activity since her alleged onset date of August 1, 2021. (R. 17.) At Step Two, the ALJ determined that Plaintiff had severe impairments of: chronic obstructive pulmonary disease (COPD), hypertension, depression, and anxiety. (Id.) The ALJ also determined that Plaintiff had non-severe impairments of heart failure and supraventricular tachycardia. (Id.) At Step Three, the ALJ found that Plaintiff did not have an impairment or combination of impairments which meet or medically equal any Listing. (R. 18-19.) The ALJ assessed Plaintiff as having the residual functional capacity (“RFC”) to perform light work with additional limitations, in relevant part, as follows: The claimant is able to perform simple, routine tasks and make simple work-related decisions. She can have occasional interaction with supervisors, co-workers, and the public.

(R. 19.) At Step Four, the ALJ found that Plaintiff could not perform her past relevant work as a home attendant, sales clerk, or janitor. (R. 23.) Based on the vocational expert’s testimony at the hearing, at Step Five, the ALJ determined that with her RFC, Plaintiff would be able to perform a significant number of jobs in the national economy, and thus that she was not disabled under the Act. (R. 24-25.)

4 The Appeals Council subsequently denied review of the opinion (R. 1), making the ALJ’s decision the final decision of the Commissioner. Bertaud v. O’Malley, 88 F.4th 1242, 1244 (7th Cir. 2023). III. Legal Standard An ALJ’s decision will be affirmed if it is supported by “substantial evidence,” which means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). “[T]he threshold for such evidentiary

sufficiency is not high.” Id. As the Seventh Circuit has made clear, ALJs are “subject to only the most minimal of articulation requirements” and “need not address every piece or category of evidence identified by a claimant, fully summarize the record, or cite support for every proposition or chain of reasoning.” Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024). “All we require is that ALJs provide an explanation for how the evidence leads to their conclusions that is sufficient to allow us, as a reviewing court, to assess the validity of the agency’s ultimate findings and afford the appellant meaningful judicial review.” Id. at 1054. See also Padua v. Bisignano, 145 F.4th 784, 789 (7th Cir. 2025) (stating that the district court’s review of the ALJ’s opinion will not “reweigh the evidence, resolve debatable evidentiary conflicts, determine credibility, or substitute our judgment for the ALJ’s”); Cain v. Bisignano, -- F.4th --, 2025 WL 2202133, at *3 (7th Cir. Aug.

4, 2025) (describing reviewing court’s role as “extremely limited”); Thorlton v. King, 127 F.4th 1078, 1080 (7th Cir. 2025) (reiterating that Seventh Circuit “review proceeds with a light touch— not holding ALJs to an overly demanding evidentiary standard and in turn reinforcing that claimants bear the affirmative burden of proving their disability”). The Seventh Circuit also has made clear that on its own review of district court decisions reviewing ALJ opinions for substantial evidence, district courts have a similar “minimal articulation” requirement: “A district (or magistrate) judge need only supply the parties . . . with enough information to follow the material reasoning underpinning a decision.” Morales v. O’Malley, 103 F.4th 469, 471 (7th Cir. 2024). IV. Analysis

Plaintiff contends the ALJ erred by failing to consider evidence as to her limitations in concentration, persistence, pace, and interaction with others. (D.E. 19: Pl. Mem. in Supp. of Reversing the Decision of the Commissioner (“Pl. Mem.”) at 6.) First, Plaintiff claims the ALJ’s discussion of her April 2022 psychological consultative exam with Dr. Laura J. Higdon, Ph.D. (“Dr. Higdon”) was inadequate in that the ALJ “never weighed” this evidence. (Id. at 9.) Second, Plaintiff argues the ALJ violated SSR 96-8p (id. at 6) because the ALJ did not mention “abnormal findings in the therapy and treatment records” beyond “stray” references. (Id. at 9-10.) The Court disagrees as to both points. A. The ALJ Did Not Err In His Discussion of The Evidence From Dr. Laura J. Higdon, Ph.D.

Plaintiff’s memorandum alleges that the ALJ “never weighed” the evidence from Dr. Higdon and that “[t]he [ALJ’s] decision is devoid of any discussion of the actual content and mental status exam findings contained in Dr. Higdon’s evaluation.” (Pl. Mem. at 7-9.) But the ALJ cited Dr. Higdon’s report throughout the Step Three analysis, and the ALJ’s discussion reveals the ALJ incorporated the observations within Dr. Higdon’s report throughout the function-by-function assessment of Plaintiff’s mental RFC. (R. 18-19, citing R. 519-22.) See Morales, 103 F.4th at 471 (providing that the ALJ must supply enough information to allow the Court to follow the material reasoning underpinning the decision).

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Crayton v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crayton-v-bisignano-ilnd-2025.