Heather M.C. L. v. Frank Bisigano, Commissioner of Social Security

District Court, M.D. Pennsylvania·Decided July 27, 2026·No. 3:23-cv-01832·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

HEATHER M.C. L.,1 CIVIL ACTION NO. 3:23-CV-01832

Plaintiff, (Magistrate Judge Latella) v.

FRANK BISIGANO,2 Commissioner of Social Security

Defendants.

MEMORANDUM This is an action brought under Section 1383(c) of the Social Security Act and 42 U.S.C. § 405(g), seeking judicial review of the final decision of the Commissioner of Social Security (hereinafter, “the

1 To protect the privacy interests of plaintiffs in social security cases, we have adopted the recommendation of the Judicial Conference of the United States that federal courts should refer to plaintiffs in such cases by their first name and last initial. See Tammy H. v. Frank Bisignano, Commissioner of Social Security, No. 1:24-cv-00838, Docket No. 19 at n.1 (M.D. Pa. Aug. 27, 2025).

2 Frank Bisignano became the Commissioner of Social Security on May 7, 2025. He has been automatically substituted in place of the original defendant, Kilolo Kijakazi. See Fed. R. Civ. P. 25(d); see also 42 U.S.C. § 405(g) (action survives regardless of any change in the person occupying the office of Commissioner of Social Security). The caption in this case is amended to reflect this change. Commissioner”) denying Plaintiff Heather M.C. L.’s claim for

supplemental security income under Title XVI of the Social Security Act. (Doc. 1). The matter has been assigned to the undersigned United States Magistrate Judge on consent of the parties, pursuant to 28

U.S.C. § 636(c) and Rule 73 of the Federal Rules of Civil Procedure. For the reasons expressed herein, and upon detailed consideration of the arguments raised by the parties in their respective briefs, the

Commissioner's decision will be vacated and remanded. I. BACKGROUND AND PROCEDURAL HISTORY

On December 11, 2020, Plaintiff Heather M.C. L. (“Ms. L”) filed an application for Title XVI benefits. (Doc. 1 at ¶ 6). In this application,

Ms. L claimed disability beginning March 20, 2019. (Id.). The Social Security Administration (“SSA”) initially denied Ms. L’s claims on May 6, 2021. (Id. at ¶ 6). The SSA denied Plaintiff’s request for

reconsideration on October 7, 2021, finding Plaintiff was not disabled. (Id.). Ms. L filed a request for a hearing before an Administrative Law Judge (“ALJ”) on October 18, 2021. (Id.). ALJ Lawrence J. Neary

conducted the requested hearing on February 24, 2022. (Id. at ¶ 8). Later, on July 6, 2022, ALJ Gwendolyn M. Hoover conducted a

supplemental hearing.3 (Id. at ¶ 8; Doc. 7-2 at 34). The supplemental hearing was necessary because Ms. L’s primary

mental health treating physician completed Ms. L’s mental residual functional capacity form from the standpoint of someone working a part-time job. (Doc. 7-2 at 35)4. Ms. L’s attorney received the form,

unexpectedly, the day before the hearing. (Doc. 7-2 at 78-79). There was not enough time for Ms. L’s treating physician to redo the form to assess Ms. L as if Ms. L were to work full-time. (Doc. 7-2 at 79). ALJ

Neary agreed to admit the incomplete form and leave the record open for 30 days for any additional record to come in. (Doc. 7-2 at 80). ALJ Neary concluded the hearing with the instruction that the hearing was

“going to be continued and [would] have to be scheduled for a supplemental hearing.” (Doc. 7-2 at 113).

3ALJ Hoover conducted the supplemental hearing because ALJ Neary was no longer available and the case was reassigned to ALJ Hoover. (Doc. 7-2 at 41).

4 For the sake of clarity, we refer, in all instances, to the ECF Document number and pagination located in the upper right-hand corner of each page. In a written opinion dated October 11, 2022, ALJ Hoover

determined that Ms. L was not disabled and therefore not entitled to the benefits sought. (Doc. 7-2 at 9). Ms. L appealed the ALJ’s decision to the Appeals Council, which, on September 22, 2023, denied Ms. L’s

request for review. (Doc. 1 at ¶ 10). On November 3, 2023, Ms. L filed the instant action. (Doc. 1). The Commissioner responded on December 14, 2023, providing the requisite transcripts from the disability

proceedings held on February 24, 2022 and July 6, 2022. (Docs. 6, 7). The parties then filed their respective briefs (Docs. 11, 14), with Ms. L alleging three errors warranting reversal or remand. (Doc. 11 at 1-2).

The parties consented to proceed before a magistrate judge on November 7, 2023. (Doc. 5). This case was reassigned to the undersigned on June 10, 2025.5

II. THE ALJ’S DECISION

On October 11, 2022, the ALJ determined: “Based on the application for supplemental security income protectively filed on

5 On June 24, 2025 we issued an Order providing the parties with notice of our intent to continue to exercise the jurisdiction previously consented to by the parties absent any express objection. (Doc. 15). No such objections were filed. December 11, 2020, [Ms. L] is not disabled under section 1614(a)(3)(A)

of the Social Security Act.” (Doc. 7-2 at 24). The ALJ reached this conclusion after proceeding through the five-step sequential analysis required by the Social Security Act. See 20 C.F.R. § 416.920.

At step one, an ALJ must determine whether the claimant is engaging in substantial gainful activity (“SGA”). 20 C.F.R § 416.920(a)(4)(i). If a claimant is engaging in SGA, the Regulations

deem them not disabled, regardless of age, education, or work experience. 20 C.F.R. § 416.920(b). SGA is defined as work activity— requiring significant physical or mental activity—resulting in pay or

profit. 20 C.F.R. § 416.910. In making this determination, the ALJ must consider only the earnings of the claimant. 20 C.F.R. § 416.974. The ALJ determined Ms. L “has not engaged in [SGA] since December

11, 2020, the application date (20 CFR 416.971 et seq.).” (Doc. 7-2 at 14). Thus, the ALJ’s analysis proceeded to step two. At step two, the ALJ must determine whether the claimant has a

medically determinable impairment that is severe or a combination of impairments that are severe. 20 C.F.R. § 416.920(a)(4)(ii). If the ALJ determines that a claimant does not have an “impairment or combination of impairments which significantly limits [the claimant’s]

physical or mental ability to do basic work activities, [the ALJ] will find that [the claimant] does not have a severe impairment and [is], therefore, not disabled.” 20 C.F.R. § 416.920(c). If a claimant

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Heather M.C. L. v. Frank Bisigano, Commissioner of Social Security, (M.D. Pa. 2026).

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