Dorothy Sims o/b/o L.D.S., a minor v. Frank J. Bisignano, Commissioner of Social Security

CourtDistrict Court, M.D. North Carolina
DecidedNovember 26, 2025
Docket1:24-cv-01081
StatusUnknown

This text of Dorothy Sims o/b/o L.D.S., a minor v. Frank J. Bisignano, Commissioner of Social Security (Dorothy Sims o/b/o L.D.S., a minor v. Frank J. Bisignano, Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dorothy Sims o/b/o L.D.S., a minor v. Frank J. Bisignano, Commissioner of Social Security, (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA DOROTHY SIMS o/b/o L.D.S., ) a minor, ) ) Plaintiff, ) ) v. ) 1:24CV1081 ) FRANK J. BISIGNANO, ) Commissioner of Social ) Security, ) ) Defendant.1 ) MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE Plaintiff, Dorothy Sims, brought this action on behalf of her minor grandchild, L.D.S., pursuant to the Social Security Act (the “Act”), to obtain judicial review of the final decision of Defendant, the Commissioner of Social Security (the “Commissioner”), denying Plaintiff’s claim for Child Supplemental Security Income (“CSSI”). (Docket Entry 1.) The Commissioner has filed the certified administrative record (Docket Entry 5 (cited herein as “Tr. __”)), and both parties have submitted dispositive briefs in accordance with Rule 5 of the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g) (Docket Entry 8 (Plaintiff’s Brief); Docket Entry 9 (Commissioner’s Memorandum); 1 The United States Senate confirmed Frank J. Bisignano as the Commissioner of the Social Security Administration on May 6, 2025, and he took the oath of office on May 7, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank J. Bisignano should substitute for Carolyn W. Colvin as the defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of Section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). Docket Entry 11 (Plaintiff’s Reply).) For the reasons that follow, the Court should enter judgment for the Commissioner. I. PROCEDURAL HISTORY Plaintiff applied for CSSI on behalf of her grandchild L.D.S. (Tr. 285-300.) Following denial of that application initially (Tr. 80-88, 104-13) and on reconsideration (Tr. 89-99, 126-33), Plaintiff requested a hearing de novo before an Administrative Law Judge (“ALJ”) (Tr. 134). Plaintiff, L.D.S., and their attorney attended the hearing. (Tr. 46-65.) The ALJ subsequently ruled that L.D.S. did not qualify as disabled under the Act. (Tr. 7-33.) The Appeals Council thereafter denied Plaintiff’s request for review (Tr. 1-6, 282-84, 446-55), thereby making the ALJ’s ruling the Commissioner’s final decision for purposes of judicial review. In rendering this disability determination, the ALJ made the following findings later adopted by the Commissioner: 1. [L.D.S.] . . . was a school-age child on June 24, 2021, the date the application was filed, and is currently a school-age child. 2. [L.D.S.] has not engaged in substantial gainful activity since June 24, 2021, the application date. . . . 3. [L.D.S.] has the following severe impairments: attention deficit hyperactivity disorder [(“ADHD”)], oppositional defiant disorder [(“ODD”)], [and] loss of voice. . . . 4. [L.D.S.] 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. -2- . . . 5. [L.D.S.] does not have an impairment or combination of impairments that functionally equals the severity of the listings. . . . 6. . . . [L.D.S.] has not been disabled, as defined in the . . . Act, since June 24, 2021, the date the application was filed. (Tr. 13-27 (bold font and internal citations omitted).) II. DISCUSSION Federal law “authorizes judicial review of the Social Security Commissioner’s denial of social security benefits.” Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). However, “the scope of . . . review of [such an administrative] decision . . . is extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). Plaintiff has not shown entitlement to relief under the extremely limited review standard. A. Standard of Review “[C]ourts are not to try [a Social Security] case de novo.” Oppenheim v. Finch, 495 F.2d 396, 397 (4th Cir. 1974). Instead, “a reviewing court must uphold the factual findings of the ALJ [underlying the denial of benefits] if they are supported by substantial evidence and were reached through application of the correct legal standard.” Hines, 453 F.3d at 561 (internal brackets and quotation marks omitted). “Substantial evidence means ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Hunter v. Sullivan, 993 F.2d 31, 34 (4th Cir. 1993) (quoting -3- Richardson v. Perales, 402 U.S. 389, 390 (1971)). “It consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance.” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (internal citations and quotation marks omitted). “If there is evidence to justify a refusal to direct a verdict were the case before a jury, then there is substantial evidence.” Hunter, 993 F.2d at 34 (internal quotation marks omitted). “In reviewing for substantial evidence, the court should not undertake to re-weigh conflicting evidence, make credibility determinations, or substitute its judgment for that of the [ALJ, as adopted by the Commissioner].” Mastro, 270 F.3d at 176 (internal brackets and quotation marks omitted). “Where conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled, the responsibility for that decision falls on the [Commissioner] (or the ALJ).” Id. at 179 (internal quotation marks omitted). “The issue before [the Court], therefore, is not whether [the claimant] is disabled, but whether the ALJ’s finding that [the claimant] is not disabled is supported by substantial evidence and was reached based upon a correct application of the relevant law.” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). When confronting that issue, the Court must take note that “[a] claimant for disability benefits bears the burden of proving a disability,” Hall v. Harris, 658 F.2d 260, 264 (4th Cir. 1981), and a child under the age of 18 qualifies as disabled if he or she has “a medically determinable physical or mental impairment or combination of impairments that causes marked and severe functional -4- limitations, and that can be expected to cause death or that has lasted or can be expected to last for a continuous period of not less than 12 months,” 20 C.F.R. § 416.906. In resolving such a claim, the ALJ must follow a three-step sequential evaluation process to consider whether a claimant (1) has engaged in substantial gainful activity; (2) has a severe impairment; and (3) has an impairment that meets or either medically or functionally equals a listed impairment. 20 C.F.R.

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Dorothy Sims o/b/o L.D.S., a minor v. Frank J. Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dorothy-sims-obo-lds-a-minor-v-frank-j-bisignano-commissioner-of-ncmd-2025.