Evangelina G. v. Frank Bisignano, Commissioner of Social Security

District Court, N.D. Illinois·Decided August 27, 2026·No. 1:23-cv-15826·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

EVANGELINA G.,1 ) ) No. 23 CV 15826 Plaintiff, ) ) v. ) Magistrate Judge Young B. Kim ) FRANK BISIGNANO, Commissioner ) of Social Security, ) ) August 27, 2026 Defendant. )

MEMORANDUM OPINION and ORDER Evangelina G. seeks disability benefits based on physical and mental impairments. She brings this action under 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of Social Security denying her application for benefits. For the following reasons, Evangelina’s remand request is denied: Procedural History Evangelina filed her benefits application in July 2021 claiming disability as of March 12, 2020. (Administrative Record (“A.R.”) 21.) After her application was denied initially and upon reconsideration at the administrative level, she sought and was granted a hearing before an Administrative Law Judge (“ALJ”), at which she and a vocational expert testified. (Id. at 38-73.) The ALJ concluded in January 2023 that Evangelina is not disabled. (Id. at 18-37.) The Appeals Council denied Evangelina’s request for review, (id. at 1-7), making the ALJ’s denial the final decision of the

1 Pursuant to Internal Operating Procedure 22, the court uses Evangelina’s first name and last initial in this opinion to protect her privacy to the extent possible. Commissioner, Jozefyk v. Berryhill, 923 F.3d 492, 496 (7th Cir. 2019). Evangelina then filed this action seeking judicial review, and the parties consented to this court’s jurisdiction. See 28 U.S.C. § 636(c); (R. 9).

Analysis Evangelina argues that the ALJ failed to: (1) supply substantial evidence to support her assigned residual functional capacity (“RFC”); (2) incorporate her mild mental impairments into her RFC; (3) properly evaluate her subjective symptom statements; and (4) compare the specific duties of her past work with the RFC. (See generally R. 17, Pl.’s Mem.) The court disagrees that the ALJ erred.

A. Symptom Assessment The court turns first to Evangelina’s complaints about the ALJ’s symptom assessment because that analysis affects other aspects of the ALJ’s decision, including the RFC assessment. An ALJ’s symptom evaluation is entitled to great deference and may only be reversed where “patently wrong.” Murphy v. Colvin, 759 F.3d 811, 815-16 (7th Cir. 2014). But the ALJ may not disregard subjective complaints “solely because they are not substantiated by objective medical evidence,”

Hall v. Colvin, 778 F.3d 688, 691 (7th Cir. 2015), and must consider factors such as medication efficacy and side effects, daily activities, treatment received, and precipitating pain factors, SSR 16-3p, 2017 WL 5180304, at *7-8 (Oct. 25, 2017). That said, the court will not disturb a symptom evaluation that is logically based on specific findings and evidence. See Murphy, 759 F.3d at 815. The ALJ’s assessment in this case meets this low bar. In concluding that Evangelina’s statements concerning the “intensity, persistence and limiting effects” of her symptoms were “not entirely consistent” with medical and other record evidence, the ALJ considered objective evidence, along with

Evangelina’s self-reports, treatment, and daily activities. (See A.R. 27-28.) Evangelina claims that the ALJ failed to analyze how her daily activities “spoke to her ability to sustain full-time work, or why they undercut [her] allegations.” (R. 17, Pl.’s Mem. at 12-13 (citing A.R. 26, 28).) But the ALJ weighed Evangelina’s statements and determined that her daily activity reports “were inconsistent with the medical evidence and other evidence in the record,” (A.R. 28), and adequately

“explain[ed the] perceived inconsistencies,” (R. 17, Pl.’s Mem. at 13 (quoting Jelinek v. Astrue, 662 F.3d 805, 812 (7th Cir. 2011))). For example, the ALJ acknowledged Evangelina’s allegations that she needed three to four daily naps and could not do laundry, go downstairs, cook, carry a gallon of milk, go for “major grocery shopping with[out] her husband,” focus, remember appointments, or stand in line. (A.R. 26, 28.) But the ALJ noted her statements that she could walk to a nearby store, do light cooking, sweep, and talk on the phone with friends, which he found conflicted with

claims that she could not perform household chores. (Id. at 26 (citing id. at 781), 32 (citing id. at 234-41, 779-84).) In addition to these inconsistencies, the ALJ relied on medical evidence, including records reflecting improvements to Evangelina’s physical impairments, to discredit her symptom statements. (See id. at 28-30 (citing id. at 643 (July 2020 report showing she had no physical activity limitations), 670 (March 2021 report noting no kidney dialysis), 685 (August 2021 examination noting she “no longer had CKD and her remaining kidney function improved”), 837-38 (January 2022 report noting no physical complaints other than constipation and breast tenderness)).).

Indeed, the ALJ cited specific findings and evidence to support his analysis. (See id. (citing id. at 631 (June 2020 examination noting Evangelina “was feeling better and less fatigued”), 659 (November 2020 examination reporting increased energy), 671- 72 (March 2021 report noting some chronic fatigue), 679-80 (June 2021 examination noting some fatigue complaints), 693 (October 2021 examination reporting improved energy and physical activity), 768-78, 838-39, 862, 969-71 (July 2020, November

2020, March 2021, January 2022, February 2022, March 2022, and July 2022 examinations revealing “normal” results and inconsistent claims of fatigue), 829 (same), 861 (March 2022 examination noting some fatigue)), 968-71 (July 2022 examination noting “she denied fatigue”)).) As such, the court declines to hold the ALJ to something higher than the governing substantial evidence standard, which he satisfied here. See Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024) (stating that an ALJ is “subject to only the most minimal of articulation

requirements”). While Evangelina asserts that the ALJ ignored evidence that she claims supports her need to nap during the day, (R. 17, Pl.’s Mem. at 13-14), the ALJ “need [not] discuss every detail in the record” as it relates to her alleged fatigue, Grotts v. Kijakazi, 27 F.4th 1273, 1278 (7th Cir. 2022) (internal citation omitted). The ALJ sufficiently explained the inconsistencies between Evangelina’s statements and the record evidence and concluded that her alleged need to nap was “not fully supported by the record, which shows only intermittent, occasional complaints of fatigue that seem related to her physical impairments.” (A.R. 28 (citing id. at 56 (testifying that

she could not stand in line at the store on only one occasion), 57 (testifying that her fatigue is medication related), 68 (same), 267-69 (July 2022 functional report describing her nap-related statements)).) The ALJ’s symptom assessment need not be “flawless,” and here it was not “patently wrong.” Simila v. Astrue, 573 F.3d 503, 517 (7th Cir. 2009) (quoting Elder v. Astrue, 529 F.3d 408, 413-14 (7th Cir. 2008)). Evangelina also criticizes the ALJ for failing to give any weight to her strong

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Evangelina G. v. Frank Bisignano, Commissioner of Social Security, (N.D. Ill. 2026).

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