James L. v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, E.D. Washington
DecidedApril 17, 2026
Docket1:25-cv-03201
StatusUnknown

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

Bluebook
James L. v. Frank Bisignano, Commissioner of Social Security, (E.D. Wash. 2026).

Opinion

2 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 3 Apr 17, 2026

4 SEAN F. MCAVOY, CLERK 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 JAMES L.,1 No. 1:25-cv-3201-EFS

8 Plaintiff, ORDER REVERSING THE 9 v. ALJ’S DENIAL OF BENEFITS, AND REMANDING FOR 10 FRANK BISIGNANO, MORE PROCEEDINGS Commissioner of Social Security, 11 Defendant. 12

13 Plaintiff James L. asks the Court to reverse the Administrative 14 Law Judge’s (ALJ) denial of Title 2 and Title 16 benefits. Plaintiff 15 contends the ALJ reversibly erred in assessing Plaintiff’s reported 16 17

18 1 For privacy reasons, Plaintiff is referred to by first name and last 19 initial or as “Plaintiff.” See LCivR 5.2(c). 20 1 mental health symptoms and the psychological medical opinions.

2 Because the ALJ improperly discounted Plaintiff’s symptom claims, the 3 ALJ erred. This error affected the formulation of the residual 4 functional capacity (RFC). Accordingly, this matter is remanded for

5 further proceedings. 6 I. Background 7 Plaintiff filed his Title 2 and Title 16 applications for benefits in

8 July 2022, when he was 29 years old, alleging disability preventing him 9 from working beginning April 20, 2022.2 He alleged physical injuries, 10 physical limitations on the left side of his body, chronic pain, anger

11 issues, memory loss, anxiety, and post-traumatic stress disorder 12 (PTSD).3 13 Plaintiff appeared for a hearing before ALJ Marc Yerkey in May

14 2025, at which Plaintiff and a vocational expert testified.4 15 16

17 2 Administrative Record (AR) 274, 281, 288. 18 3 AR 86, 101, 377, 379–81, 384 19 4 AR 42–83. 20 1 After the hearing, the ALJ issued a decision finding Plaintiff not

2 disabled.5 The ALJ found Plaintiff’s alleged symptoms were “not 3 entirely consistent” with the medical evidence and other evidence.6 As 4 to the medical opinions, the ALJ found:

5 • the administrative findings of the State agency psychological 6 consultant persuasive; and 7 • the consultative opinions of Marquetta Washington, ARNP,

8 Thomas Genthe, PhD, Dana Harmon, PhD, and Joyce Austin, 9 PMHNP, not persuasive.7 10 As to the sequential disability analysis, the ALJ found:

11 • Plaintiff met the insured status requirements through March 12 31, 2027. 13

14 5 AR 14. Per 20 C.F.R. §§ 404.1520(a)–(g), 416.920(a)–(g), a five-step 15 evaluation determines whether a claimant is disabled. 16 6 AR 22. As recommended by the Ninth Circuit in Smartt v. Kijakazi, 17 the ALJ should consider replacing the phrase “not entirely consistent” 18 with “inconsistent.” 53 F.4th 489, 499, n.2 (9th Cir. 2022). 19 7 AR 25–26. 20 1 • Step one: Plaintiff had not engaged in substantial gainful

2 activity since April 20, 2022, the alleged onset date. 3 • Step two: Plaintiff had the following medically determinable 4 severe impairments: major depressive disorder; anxiety

5 disorder; borderline personality disorder; PTSD; and substance 6 use disorder. 7 • Step three: Plaintiff did not have an impairment or

8 combination of impairments that met or medically equaled the 9 severity of one of the listed impairments. 10 • RFC: Plaintiff had the RFC to perform a full range of work at

11 all exertional levels, except Plaintiff could understand, 12 remember, and carry out only simple instructions; could have 13 only occasional interactions with others; and could deal with

14 only occasional changes in a routine work setting. 15 • Step four: Plaintiff had no past relevant work. 16 • Step five: considering Plaintiff’s RFC, age, education, and work

17 history, Plaintiff could perform work that existed in significant 18 19

20 1 numbers in the national economy, such as hand packager, auto

2 detailer, cleaner, marker, router, or collator.8 3 Plaintiff timely requested review of the ALJ’s decision by the 4 Appeals Council, which denied review.9 Plaintiff now appeals to district

5 court.10 6 II. Standard of Review 7 The ALJ’s decision is reversed “only if it is not supported by

8 substantial evidence or is based on legal error”11 and such error 9 impacted the nondisability determination.12 Substantial evidence is 10

11 8 AR 19–27. 12 9 AR 1. 13 10 ECF No. 1. 14 11 Hill v. Astrue, 698 F.3d 1153, 1158 (9th Cir. 2012). See 42 U.S.C. § 15 405(g). 16 12 Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012), superseded on 17 other grounds by 20 C.F.R. § 416.920(a) (recognizing that the court may 18 not reverse an ALJ decision due to a harmless error—one that “is 19 inconsequential to the ultimate nondisability determination”). 20 1 “more than a mere scintilla but less than a preponderance; it is such

2 relevant evidence as a reasonable mind might accept as adequate to 3 support a conclusion.”13 4 III. Analysis

5 Plaintiff does not challenge the ALJ’s findings regarding his 6 physical health and limitations; instead, he narrows his appeal to 7 issues regarding his mental health.14 He argues the ALJ reversibly

9 13 Hill, 698 F.3d at 1159 (quoting Sandgathe v. Chater, 108 F.3d 978, 10 980 (9th Cir. 1997)). See also Lingenfelter v. Astrue, 504 F.3d 1028, 11 1035 (9th Cir. 2007) (The court “must consider the entire record as a 12 whole, weighing both the evidence that supports and the evidence that 13 detracts from the Commissioner’s conclusion,” not simply the evidence 14 cited by the ALJ or the parties) (cleaned up); Black v. Apfel, 143 F.3d 15 383, 386 (8th Cir. 1998) (“An ALJ’s failure to cite specific evidence does 16 not indicate that such evidence was not considered[.]”). 17 14 See Nadon v. Bisignano, 145 F.4th 1133, 1138 (9th Cir. 2025) 18 (deciding that the claimant forfeited an argument by not challenging 19 the ALJ’s findings in that regard). 20 1 erred by not properly assessing Plaintiff’s alleged mental symptoms

2 and the psychological medical opinions. In response, the Commissioner 3 argues the ALJ committed no error and that substantial evidence 4 supports the ALJ’s reasons for discounting Plaintiff’s alleged

5 symptoms, weighing of the medical opinions, and nondisability 6 decision. As is explained below, the ALJ consequentially erred when 7 evaluating Plaintiff’s reports of the symptoms caused by his mental

8 disorders, thereby impacting the RFC. 9 A. Symptom Reports: Plaintiff establishes consequential 10 error.

11 Plaintiff argues the ALJ erred by not properly assessing 12 Plaintiff’s alleged symptoms, asserting that six of the ALJ’s relevant 13 findings were either not supported by the record or not sufficiently

14 clear and convincing reasons to discount his reported symptoms: 15 (1) that Plaintiff had conservative mental treatment; (2) that Plaintiff’s 16 mental symptoms were generally well controlled; (3) that objective

17 findings were unremarkable; (4) that Plaintiff attended only three 18 therapy sessions; (5) that Plaintiff had a relatively normal degree of 19 functioning; and (6) that Plaintiff had stated he was willing to work.

20 1 1. Standard

2 After finding a medically determinable impairment, the ALJ 3 must assess the intensity and persistence of the alleged symptoms to 4 determine how they affect the claimant’s ability to work.15 Factors the

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Bluebook (online)
James L. v. Frank Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-l-v-frank-bisignano-commissioner-of-social-security-waed-2026.