Mark Fleming v. Frank Bisignano, Commissioner, Social Security Administration

District Court, E.D. Arkansas·Decided August 5, 2026·No. 3:26-cv-00038·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

MARK FLEMING PLAINTIFF

v. 3:26-cv-00038-LPR-JJV

FRANK BISIGNANO, Commissioner, Social Security Administration, DEFENDANT

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION

INSTRUCTIONS

This recommended disposition has been submitted to United States District Judge Lee P. Rudofsky. The parties may file specific objections to these findings and recommendations and must provide the factual or legal basis for each objection. The objections must be filed with the Clerk no later than fourteen (14) days from the date of the findings and recommendations. A copy must be served on the opposing party. The district judge, even in the absence of objections, may reject these proposed findings and recommendations in whole or in part. RECOMMENDED DISPOSITION Mark Fleming has appealed the final decision of the Commissioner of the Social Security Administration to deny his claim for disability insurance benefits and supplemental security income. The Administrative Law Judge (ALJ) concluded he had not been under a disability within the meaning of the Social Security Act, because jobs existed in significant numbers he could perform despite his impairments. (Tr. 16-28.) This review function is extremely limited. A court’s function on review is to determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole and to analyze whether Plaintiff was denied benefits due to legal error. Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997); see also, 42 U.S.C. § 405(g). Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Richardson v. Perales, 402 U.S. 389, 401 (1971); Reynolds v. Chater, 82 F.3d 254, 257 (8th Cir. 1996). In assessing the substantiality of the evidence, courts must consider evidence that detracts from the Commissioner’s decision as well as evidence that supports it; a court may not, however,

reverse the Commissioner’s decision merely because substantial evidence would have supported an opposite decision. Woolf v. Shalala, 3 F.3d 1210, 1213 (8th Cir. 1993). The history of the administrative proceedings and the statement of facts relevant to this decision are contained in the respective briefs and are not in serious dispute. Therefore, they will not be repeated in this opinion except as necessary. After careful review of the pleadings and evidence in this case, I find the Commissioner’s decision is supported by substantial evidence and Plaintiff’s Complaint should be DISMISSED. Plaintiff is fifty-three years old. (Tr. 38.) He went as far as the tenth grade in school (id.) and has past relevant work as a funeral attendant. (Tr. 26.)

The ALJ1 first found Mr. Fleming was eligible to apply for disability insurance benefits and had not engaged in substantial gainful activity since March 28, 2023 – the alleged onset date. (Tr. 19.) He has “severe” impairments in the form of degenerative disc disease of the cervical and lumbar spine; diabetes mellitus; peripheral neuropathy; and obesity. (Id.) The ALJ further found

1 The ALJ followed the required sequential analysis to determine: (1) whether the claimant was engaged in substantial gainful activity; (2) if not, whether the claimant had a severe impairment; (3) if so, whether the impairment (or combination of impairments) met or equaled a listed impairment; and (4) if not, whether the impairment (or combination of impairments) prevented the claimant from performing past relevant work; and (5) if so, whether the impairment (or combination of impairments) prevented the claimant from performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 416.920(a)-(g) and 404.1520(a)-(g). Plaintiff did not have an impairment or combination of impairments meeting or equaling an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1.2 (Tr. 20.) The ALJ determined Mr. Fleming maintained the residual functional capacity (RFC) to perform a reduced range of light work. (Id.) Because Plaintiff’s past work exceeded his RFC, the ALJ utilized the services of a vocational expert to determine if jobs existed that Plaintiff could

perform despite his impairments. (Tr. 52-56.) Based in part on the testimony of the vocational expert, the ALJ determined he could perform the jobs of office helper, non-postal mail clerk, and router - despite his limitations. (Tr. 27.) Accordingly, the ALJ determined Mr. Fleming was not disabled. (Tr. 28.) The Appeals Council denied Plaintiff’s request for a review of the ALJ’s decision, making his decision the final decision of the Commissioner. (Tr. 4-12.) Plaintiff filed the instant Complaint initiating this appeal. (Doc. No. 2.) In support of his Complaint, Mr. Fleming argues that the ALJ’s RFC assessment was flawed. (Doc. No. 8 at 8-18.) Plaintiff says:

The record contains three materially different functional assessments. First, Dr. Holder, the consultative examiner, found moderate to severe limitations in bending, standing, walking, lifting, carrying, balancing, climbing, using foot controls, and grasping. (Tr. at 651). Those limitations were grounded in objective findings that included reduced strength in all extremities, abnormal gait, limited spinal and shoulder motion, inability to heel-toe walk, inability to squat and rise, and reduced grip strength. (Tr. at 649-53).

Second, Dr. Murphy reached a significantly less restrictive conclusion. Though Dr. Murphy accepted Dr. Holder’s opinion by explicitly stating that it was consistent with the RFC findings and summarizing his opinion, including the moderate to severe grasping limits – Dr. Murphy found that Plaintiff could perform light work, could stand or walk about six hours in an eight hour workday, and had no manipulative limitations at all. (Tr. at 69-72). Third, Dr. Bates assessed a different and more restrictive RFC. Although she also accepted Dr. Holder’s opinion by explicitly stating that it was consistent with the

2 20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526. RFC findings and summarizing his opinion, including the moderate to severe grasping limits – Dr. Bates limited Plaintiff to four hours of standing or walking in an eight hour workday, restricted certain postural activities to occasional, (climbing ramps and stairs), and added a manipulative limitation of occasional overhead reaching bilaterally. (Tr. at 87-88). These are not minor differences. They concern the core work functions that determine whether Plaintiff can sustain light work at all: standing, walking, postural activity, and upper extremity use. These materially different functional assessments were not reconciled by ALJ Sharp in his RFC assessment.

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Mark Fleming v. Frank Bisignano, Commissioner, Social Security Administration, (E.D. Ark. 2026).

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