Liza S. v. Frank Bisignano, Commissioner of the Social Security Administration

District Court, D. New Mexico·Decided December 11, 2025·No. 2:24-cv-01265·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO

LIZA S.,1 Plaintiff, v. 2:24-cv-01265-JMR

FRANK BISIGNANO,2 Commissioner of the Social Security Administration,

Defendant. MEMORANDUM OPINION AND ORDER

THIS MATTER comes before the Court on plaintiff Liza S.’s Opening Brief (Doc. 16), filed on April 22, 2025. Doc. 16. Defendant filed a response. Doc. 22. Plaintiff did not file a reply, and the time for doing so has now passed. See Doc. 7 (Plaintiff’s reply due fourteen days after Commissioner’s response). The parties consented to my entering final judgment in this case. Docs. 5, 9, 10. Having meticulously reviewed the entire record and being fully advised in the premises, I find that Plaintiff’s motion is not well-taken, and it will be DENIED. I. Standard of Review The standard of review in a Social Security appeal is whether the Commissioner’s final decision3 is supported by substantial evidence and whether the correct legal standards were

1 Due to sensitive personal and medical information contained in this opinion, the Court uses only the plaintiff’s first name and last initial. In so doing, the Court balances the plaintiff’s privacy interest in her personal medical information, United States v. Dillard, 795 F.3d 1191, 1205–06 (10th Cir. 2015), and the public’s interest in accessing the opinion, FED. R. CIV. P. 5.2(c)(2)(B).

2 Frank Bisignano became the Commissioner of the Social Security Administration on May 7, 2025, and is automatically substituted as the defendant in this action. FED. R. CIV. P. 25(d).

3 The Court’s review is limited to the Commissioner’s final decision, 42 U.S.C. § 405(g), which generally is the ALJ’s decision, 20 C.F.R. § 416.1481, as it is in this case. applied. Maes v. Astrue, 522 F.3d 1093, 1096 (10th Cir. 2008). If substantial evidence supports the Commissioner’s findings and the correct legal standards were applied, the Commissioner’s decision stands, and the plaintiff is not entitled to relief. Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). “The failure to apply the correct legal standard or to provide this court

with a sufficient basis to determine that appropriate legal principles have been followed is grounds for reversal.” Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005) (internal quotation marks and brackets omitted). The Court must meticulously review the entire record, but it may neither reweigh the evidence nor substitute its judgment for that of the Commissioner. Flaherty v. Astrue, 515 F.3d 1067, 1070 (10th Cir. 2007). “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Langley, 373 F.3d at 1118. A decision “is not based on substantial evidence if it is overwhelmed by other evidence in the record or if there is a mere scintilla of evidence supporting it.” Id. While the Court may not reweigh the evidence or try the issues de novo, its examination of the record as a whole must include “anything that may

undercut or detract from the ALJ’s findings in order to determine if the substantiality test has been met.” Grogan v. Barnhart, 399 F.3d 1257, 1262 (10th Cir. 2005). “The possibility of drawing two inconsistent conclusions from the evidence does not prevent [the] findings from being supported by substantial evidence.” Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (quoting Zoltanski v. F.A.A., 372 F.3d 1195, 1200 (10th Cir. 2004)). II. Applicable Law

The Commissioner’s regulations provide that a claimant must complete a four-step administrative review process to obtain a judicially reviewable final decision. 20 C.F.R. § 416.1400(a).4 This four-step process includes an initial determination (step one), a claimant’s request for reconsideration of the initial determination (step two), a claimant’s request for a hearing by an ALJ (step three), and a claimant’s request for review of the ALJ’s decision by the Appeals Council (step four). 20 C.F.R. §§ 416.1400(a), 416.1402, 416.1404(b), 416.1407,

416.1429, 416.1430, 416.1467, 416.1481, 422.210; see also Smith v. Berryhill, 587 U.S. 471, 475–76 (2019). At step three, if a claimant fails to timely request a hearing and the ALJ does not find good cause for a claimant’s untimeliness, the ALJ may dismiss the request for a hearing. 20 C.F.R. § 416.1457(c)(3). In determining whether claimant has good cause for failing to timely request a hearing, the ALJ will consider any physical, mental, educational, or linguistic limitations that a claimant might have. 20 C.F.R. § 416.1411(a)(4). The claimant may ask the ALJ or the Appeals Council to vacate the dismissal. 20 C.F.R. § 416.1460(a). The ALJ or Appeals Council will vacate the dismissal only if the claimant shows the dismissal was erroneous. Id.

III. Background and Procedural History Plaintiff filed an application for Supplemental Security Income (“SSI”) on December 9,

4 This Court has jurisdiction to review “any final decision of the [agency] made after a hearing to which [Plaintiff] was a party. . . .” 42 U.S.C. § 405(g). Courts are split on whether they have jurisdiction to review a case where no ALJ hearing has been held. The Tenth Circuit has not addressed the issue. The Court, however, is persuaded by those courts finding jurisdiction in these circumstances. See Curlee v. Comm'r of Soc. Sec., No. 1:20-CV-00145-SAB, 2022 WL 993005, at *3 (E.D. Cal. Apr. 1, 2022), aff'd sub nom. Curlee v. O'Malley, No. 22-15655, 2024 WL 2103275 (9th Cir. May 10, 2024) (collecting cases and explaining why the reasoning in Smith v. Berryhill, 587 U.S. 471 (2019), while not directly on point, warrants finding jurisdiction when the ALJ has dismissed a request for a hearing). In addition, the Commissioner elected “not to invoke § 405(g) as a potential bar to judicial review and accept[ed] the Court’s authority to review the ALJ’s dismissal of Plaintiff’s hearing request. . . .” Doc. 22 at 2. 2021.5 AR 30–35. The Social Security Administration (“SSA”) denied her claim initially on July 5, 2022. AR 26–29. Plaintiff filed a request for reconsideration on July 13, 2022. AR 22– 24. The SSA denied her claim on reconsideration on August 10, 2023. AR 19–21. The SSA notified Plaintiff that she had 60 days to ask for a hearing by an Administrative Law Judge

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Liza S. v. Frank Bisignano, Commissioner of the Social Security Administration, (D.N.M. 2025).

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Related

Zoltanski v. Federal Aviation Administration
372 F.3d 1195 (Tenth Circuit, 2004)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Maes v. Astrue
522 F.3d 1093 (Tenth Circuit, 2008)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
United States v. Dillard
795 F.3d 1191 (Tenth Circuit, 2015)
Smith v. Berryhill
587 U.S. 471 (Supreme Court, 2019)