Jo Ann S. v. Frank J. Bisignano, Commissioner of Social Security

District Court, M.D. North Carolina·Decided July 27, 2026·No. 1:25-cv-00858·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA JO ANN S., ) ) Plaintiff, ) ) v. ) 1:25CV858 ) FRANK J. BISIGNANO, ) Commissioner of Social ) Security, ) ) Defendant.1 ) MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE Plaintiff, Jo Ann S., brought this action 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 Disability Insurance Benefits (“DIB”). (Docket Entry 2.) The Commissioner has filed the certified administrative record (Docket Entry 4 (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 11 (Commissioner’s 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 as Defendant in this suit. Neither the Court nor the parties need take further action 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). Brief); Docket Entry 12 (Plaintiff’s Reply)). For the reasons that follow, the Court should enter judgment for the Commissioner. I. PROCEDURAL HISTORY Plaintiff applied for DIB (Tr. 220-21), alleging a disability onset date of November 4, 2021 (see Tr. 220). Upon denial of that application initially (Tr. 89-99, 115-24) and on reconsideration (Tr. 100-09, 126-33), Plaintiff requested a hearing de novo before an Administrative Law Judge (“ALJ”) (Tr. 134). Plaintiff, her attorney, and a vocational expert (“VE”) attended the hearing. (Tr. 37-88.) The ALJ subsequently ruled that Plaintiff did not qualify as disabled under the Act. (Tr. 14-36.) The Appeals Council thereafter denied Plaintiff’s request for review (Tr. 1-6, 216-18, 337-69), thereby making the ALJ’s ruling the Commissioner’s final decision for purposes of judicial review. In rendering that decision, the ALJ made the following findings later adopted by the Commissioner: 1. [Plaintiff] meets the insured status requirements of the . . . Act through December 31, 2026, as confirmed by her certified earnings record. 2. [Plaintiff] has not engaged in substantial gainful activity since November 4, 2021, the alleged onset date. . . . 3. [Plaintiff] has the following severe impairments: degenerative joint disease of the right knee; status post arthroscopic surgery of the right knee; degenerative disc disease; obesity; and asthma. . . . 2 4. [Plaintiff] 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. . . . 5. . . . [Plaintiff] has the residual functional capacity to perform light work . . . except she can stand and/or walk for up to one hour at a time, followed by at least fifteen minutes of work in a seated position; she can stand and/or walk [f]or up [to] four hours in an eight-hour day. She can sit for up to six hours in an eight-hour workday. [She] can lift and/or carry twenty pounds occasionally and ten pounds frequently. She can frequently balance and stoop. She can occasionally kneel, crouch, and crawl. [She] can never climb ladders, ropes, poles, or scaffolds. She can frequently climb ramps and stairs. She should avoid concentrated exposure to heat; humidity; wetness; workplace hazards, such as unprotected heights and moving machine parts; and pulmonary irritants such as fumes, dust, gases, and poor ventilation.

. . . 6. [Plaintiff] is unable to perform any past relevant work. . . . 10. Considering [Plaintiff]’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that [Plaintiff] can perform. . . .

11. [Plaintiff] has not been under a disability, as defined in the . . . Act, from November 4, 2021, through the date of th[e ALJ’s] decision. (Tr. 19-30 (bold font and internal parenthetical citations omitted).) 3 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 a] decision . . . is extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). Plaintiff has not established 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. 1992) (quoting 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 brackets and quotation marks omitted). “If

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Jo Ann S. v. Frank J. Bisignano, Commissioner of Social Security, (M.D.N.C. 2026).

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