Lisa Daugherty v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedNovember 19, 2025
Docket4:24-cv-00811
StatusUnknown

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

Bluebook
Lisa Daugherty v. Frank Bisignano, Commissioner of Social Security, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

LISA DAUGHERTY, : Civil No. 4:24-CV-811 : Plaintiff, : : v. : (Magistrate Judge Carlson) : FRANK BISIGNANO,1 : Commissioner of Social Security : : Defendant. :

MEMORANDUM OPINION

I. Introduction The plaintiff, Lisa Daugherty, appeals from a decision of an Administrative Law Judge (ALJ) denying her application for disability benefits. According to Daugherty she has been totally disabled since June of 2020 when she alleges that she suffered a series of “mini strokes” which compounded her other pre-existing physical and emotional impairments. Yet, this claim of complete disability beginning in June of 2020 was contradicted by Daugherty’s own reports of her

1 Frank Bisignano became the Commissioner of Social Security on May 6, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank Bisignano should be substituted as the defendant in this suit. No further action need be taken 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).

1 activities of daily living following the alleged onset of her disability. These reports included statements in July of 2021 by Daugherty that she “has been working out

with aerobic exercise, weight training”, (Tr. 568), and Daugherty’s September 2021 report that “3 weeks ago she was completing her morning exercises like usually [sic] and then went to go shoot pool for a few hours.” (Tr. 720, 727).

Moreover, with respect to Daugherty’s claim that she suffered multiple “mini strokes” in June of 2020, her description of these events conflicts with contemporaneous treatment notes and imaging test results. These clinical test results led physicians to doubt that she had experienced any strokes. Further, these records

indicated that Daugherty declined medical testing in June of 2020 to determine whether she had suffered a stroke. (Tr. 373-415, 458-486). Presented with this equivocal clinical evidence, Daugherty’s own inconsistent

statements, and an array of medical opinions, many of which found that she retained the ability to perform some work, the ALJ ultimately concluded that Daugherty had not met the exacting standards prescribed for disability under the Social Security Act and denied her claim. While Daugherty now challenges this decision on several

grounds, she faces an exacting burden of proof and persuasion in this appeal since our analysis of this case cabined by the “substantial evidence” standard of review in Social Security cases, which is limited by the Supreme Court’s mandate that:

2 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. ––––, ––––, 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, this Court has said, is “more than a mere scintilla.” Ibid.; see, e.g., Perales, 402 U.S. at 401, 91 S. Ct. 1420 (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, 139 S. Ct. 1148, 1154 (2019). Under this standard of review, we are obliged to affirm the decision of the administrative law judge (ALJ) once we find that it is “supported by substantial evidence, ‘even [where] this court acting de novo might have reached a different conclusion.’” Monsour Med. Ctr. v. Heckler, 806 F.2d 1185, 1190–91 (3d Cir. 1986) (quoting Hunter Douglas, Inc. v. NLRB, 804 F.2d 808, 812 (3d Cir. 1986)). Mindful of these legal mandates, after a review of the record, and acknowledging that in this setting substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’”

3 Biestek, 139 S. Ct. at 1154, we find that substantial evidence supported the ALJ’s findings in this case. Therefore, for the reasons set forth below, we will affirm the

decision of the Commissioner denying this claim. II. Statement of Facts and of the Case

A. Background

On August 19, 2021, Lisa Daugherty applied for benefits under Title II of the Social Security Act, alleging an onset of disability beginning June 9, 2020. (Tr. 11). According to Daugherty, the triggering event which led to her total disability occurred “when I suffered two mini-strokes in less than a week in June of 2020,” after which her “health took a steady decline.” (Tr. 59-60). Thus, Daugherty insisted that this rapid succession of mini-strokes in June of 2020 exacerbated a series of other medical conditions, including lumbar degenerative disc disease, cervical

spondylosis, migraine headaches, gastroesophageal reflux disease (GERD), depression, generalized anxiety disorder, post-traumatic stress disorder (PTSD), and substance abuse disorder—marijuana, and left her unable to work. (Tr. 13). Daugherty’s date last insured was September 30, 2022. (Tr. 13). Therefore,

the issue before the ALJ was whether Daugherty’s impairments were so severe during this roughly two year time frame between June 2020 and September 2022 that she was unable to work. Daughtery was born in April 1970 and was 50 years

4 old at the time of this alleged onset of her disability. (Tr. 24). She had a high school education but had only a sporadic, episodic work history. (Id.) Prior to the alleged

onset of her disability in June of 2020 Daugherty reported an active lifestyle that involved housework, hiking, aerobic exercise, weight training, and shooting pool. (Tr. 45, 60). There were also indications in the clinical record that Daugherty was

employed after the date of her alleged onset of disability.2 B. The Lack of Clinical Support for Daughtery’s Claim that She Experienced Strokes in June 2020.

As framed by Daugherty the factual lynchpin for her disability claim was her allegation that “I suffered two mini-strokes in less than a week in June of 2020,” after which her “health took a steady decline.” (Tr. 59-60). However, these allegations that Daugherty suffered multiple strokes in June 2020, drew scant support from the clinical record. To be sure, Daugherty was treated at the York Hospital Emergency

Department on June 3, 2020, when she reported suffering from weakness and

2 See Tr. 815, a March 15, 2022 medical entry indicating that Daugherty was seeking a “note for her job stating that she is safe to drive while being on medication.” This request for a note for her employer was made some twenty-one months after the date that the plaintiff alleged that her impairments were so severe that they precluded any employment.

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