Johnson v. Bisignano

CourtDistrict Court, S.D. Alabama
DecidedSeptember 30, 2025
Docket2:24-cv-00202
StatusUnknown

This text of Johnson v. Bisignano (Johnson v. Bisignano) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnson v. Bisignano, (S.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA NORTHERN DIVISION IDA ALETHEA JOHNSON, ) Plaintiff, ) ) v. ) CIVIL ACTION NO. 2:24-00202-N ) FRANK BISIGNANO, ) Commissioner of Social Security, 1 ) Defendant. )

MEMORANDUM OPINION AND ORDER

Plaintiff Ida Alethea Johnson brought this action under 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of a final decision of the Defendant Commissioner of Social Security denying her applications for a period of disability and disability insurance benefits (collectively, “DIB”) under Title II of the Social Security Act, 42 U.S.C. § 401, et seq., and supplemental security income (“SSI”) under

1 Frank Bisignano’s nomination to be Commissioner of Social Security was confirmed on May 6, 2025, and he began his term of service the following day. See:

• https://www.congress.gov/nomination/119th-congress/20 (last visited 9/30/2025)

• https://www.ssa.gov/history/commissioners.html (last visited 9/30/2025)

Accordingly, Bisignano was automatically substituted for former Acting Commissioner Carolyn Colvin as the party defendant in this action under Federal Rule of Civil Procedure 25(d), and this change does not affect the pendency of this action. See 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). The Clerk of Court is DIRECTED to update the title of this case on the docket accordingly. Title XVI of the Social Security Act, 42 U.S.C. § 1381, et seq.2 Upon due consideration of the parties’ briefs (Docs# 14, 15) and those portions of the certified transcript of the administrative record (Docs# 11 & 11-1) relevant to the issues raised, and with the

benefit of oral argument, the Court finds that the Commissioner’s final decision is due to be AFFIRMED.3 I. Procedural Background Johnson filed the subject DIB and SSI applications with the Social Security Administration (“SSA”) on April 25, 2022. After the applications were denied initially, and again on reconsideration, Johnson requested a hearing on her application with an Administrative Law Judge (“ALJ”) of the SSA’s Office of Hearings Operations. The

hearing was held on January 4, 2024. On April 2, 2024, the ALJ issued an unfavorable decision on Johnson’s applications, finding her not entitled to benefits. (See Doc# 11- 1, PageID.41-64). The Commissioner’s decision on Johnson’s applications became final when the Appeals Council with the SSA’s Office of Appellate Operations denied her request for

2 “Title II of the Social Security Act (Act), 49 Stat. 620, as amended, provides for the payment of insurance benefits to persons who have contributed to the program and who suffer from a physical or mental disability. 42 U.S.C. § 423(a)(1)(D) (1982 ed., Supp. III). Title XVI of the Act provides for the payment of disability benefits to indigent persons under the Supplemental Security Income (SSI) program. § 1382(a).” Bowen v. Yuckert, 482 U.S. 137, 140, 107 S. Ct. 2287, 96 L. Ed. 2d 119 (1987).

3 With the consent of the parties, the Court has designated the undersigned Magistrate Judge to conduct all proceedings and order the entry of judgment in this civil action, in accordance with 28 U.S.C. § 636(c), Federal Rule of Civil Procedure 73, and S.D. Ala. GenLR 73. (See Docs# 8, 9). With the Court’s agreement, the parties waived the opportunity to present oral argument. (See Docs# 17, 18). review of the ALJ’s unfavorable decision on May 3, 2024. (See id., PageID.35-39). Johnson subsequently brought this action under §§ 405(g) and 1383(c)(3) for judicial review of the Commissioner’s second final decision. See 42 U.S.C. § 1383(c)(3) (“The

final determination of the Commissioner of Social Security after a hearing [for SSI benefits] shall be subject to judicial review as provided in section 405(g) of this title to the same extent as the Commissioner’s final determinations under section 405 of this title.”); 42 U.S.C. § 405(g) (“Any individual, after any final decision of the Commissioner of Social Security made after a hearing to which he was a party, irrespective of the amount in controversy, may obtain a review of such decision by a civil action commenced within sixty days after the mailing to him of notice of such

decision or within such further time as the Commissioner of Social Security may allow.”). II. Standards of Review “In Social Security appeals, [the Court] must determine whether the Commissioner’s decision is supported by substantial evidence and based on proper legal standards.” Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir.

2011) (quotation omitted). The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. [293], [301], 135 S. Ct. 808, 815, 190 L. Ed. 2d 679 (2015). Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains “sufficien[t] evidence” to support the agency’s factual determinations. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L. Ed. 126 (1938) (emphasis deleted). And whatever the meaning of “substantial” in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence … is “more than a mere scintilla.” Ibid.; see, e.g., [Richardson v.] Perales, 402 U.S. [389,] 401, 91 S. Ct. 1420[, 28 L. Ed. 2d 842 (1971)] (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L. Ed. 2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly-erroneous standard). Biestek v. Berryhill, 587 U.S. 97, 102-03, 139 S. Ct. 1148, 203 L. Ed. 2d 504 (2019). In reviewing the Commissioner’s factual findings, a court “‘may not decide the facts anew, reweigh the evidence, or substitute our judgment for that of the [Commissioner].’ ” Winschel, 631 F.3d at 1178 (quoting Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004) (alteration in original) (quoting Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983))).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Newton v. Apfel
209 F.3d 448 (Fifth Circuit, 2000)
Geraldine Caldwell v. Michael J. Astrue
261 F. App'x 188 (Eleventh Circuit, 2008)
Miles v. Chater
84 F.3d 1397 (Eleventh Circuit, 1996)
Crayton v. Callahan
120 F.3d 1217 (Eleventh Circuit, 1997)
Falge v. Apfel
150 F.3d 1320 (Eleventh Circuit, 1998)
Jones v. Apfel
190 F.3d 1224 (Eleventh Circuit, 1999)
Andrew T. Wilson v. Jo Anne B. Barnhart
284 F.3d 1219 (Eleventh Circuit, 2002)
Ellison v. Barnhart
355 F.3d 1272 (Eleventh Circuit, 2003)
Renee S. Phillips v. Jo Anne B. Barnhart
357 F.3d 1232 (Eleventh Circuit, 2004)
Billy D. Crawford v. Comm. of Social Security
363 F.3d 1155 (Eleventh Circuit, 2004)
Bobby Dyer v. Jo Anne B. Barnhart
395 F.3d 1206 (Eleventh Circuit, 2005)
Christi L. Moore v. Jo Anne B. Barnhart
405 F.3d 1208 (Eleventh Circuit, 2005)
Ingram v. Commissioner of Social Security Administration
496 F.3d 1253 (Eleventh Circuit, 2007)
Singh v. US Atty. Gen.
561 F.3d 1275 (Eleventh Circuit, 2009)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Federal Power Commission v. Texaco Inc.
417 U.S. 380 (Supreme Court, 1974)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Dickinson v. Zurko
527 U.S. 150 (Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Johnson v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-bisignano-alsd-2025.