Miguel D. v. Frank Bisignano, Commissioner of Social Security

District Court, N.D. Illinois·Decided April 8, 2026·No. 1:23-cv-01448·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

MIGUEL D.,1 ) ) No. 23 CV 1448 Plaintiff, ) ) v. ) Magistrate Judge Young B. Kim ) FRANK BISIGNANO, Commissioner ) of Social Security, ) ) April 8, 2026 Defendant. )

MEMORANDUM OPINION and ORDER Miguel D. seeks supplemental security income based on a combination of physical and mental impairments he says prevents him from working. He brings this action pursuant to 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of Social Security denying his application for benefits. For the following reasons, Miguel’s remand request is denied: Procedural History Miguel filed his benefits application in October 2019 claiming disability onset on January 1, 2016. (Administrative Record (“A.R.”) 19, 178-86.) After his application was denied at the administrative level, (id. at 69-80, 82-105), he sought and was granted a hearing before an Administrative Law Judge (“ALJ”), where he and a vocational expert testified, (id. at 43-68, 124-26). The ALJ concluded in June 2022 that Miguel is not disabled. (Id. at 19-36.) After the Appeals Council denied

1 Pursuant to Internal Operating Procedure 22, the court uses Miguel’s first name and last initial in this opinion to protect his privacy to the extent possible. Miguel’s request for review, (id. at 1-6), he sought judicial review, and the parties consented to this court’s jurisdiction, 28 U.S.C. § 636(c); (R. 7). Analysis

Miguel argues that the ALJ: (1) improperly evaluated his subjective symptom statements; (2) incorrectly assessed psychological consultative examiner (“CE”) Dr. Michael Stone’s opinion; and (3) failed to supply substantial evidence to support the assigned mental residual functional capacity (“RFC”). (See generally R. 17, Pl.’s Br.) When reviewing the ALJ’s decision, the court asks only whether the ALJ applied the correct legal standards and the decision has the support of substantial evidence,

Burmester v. Berryhill, 920 F.3d 507, 510 (7th Cir. 2019), which is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quotation and citations omitted). This deferential standard precludes the court from reweighing evidence or substituting its judgment for the ALJ’s, allowing reversal “only if the record compels” it. Deborah M. v. Saul, 994 F.3d 785, 788 (7th Cir. 2021) (quotation and citation omitted). However, the ALJ’s “analysis must say enough to enable a review of

whether the ALJ considered the totality of a claimant’s limitations,” Lothridge v. Saul, 984 F.3d 1227, 1233 (7th Cir. 2021), and “provide an explanation . . . that is ‘sufficient to allow [the] reviewing court[ ] to assess the validity of the agency’s ultimate findings and afford [the claimant] meaningful judicial review,’” Warnell v. O’Malley, 97 F.4th 1050, 1054 (7th Cir. 2024) (quoting Moore v. Colvin, 743 F.3d 1118, 1121 (7th Cir. 2014)). Viewing the record under this standard, remand is not warranted. A. Symptom Evaluation

The court turns first to Miguel’s argument that the ALJ did not properly evaluate his symptom statements because that analysis informs several other aspects of the ALJ’s decision, including the RFC assessment. (R. 17, Pl.’s Br. at 14-16.) An ALJ’s symptom evaluation is entitled to great deference and may be reversed only where “patently wrong.” Murphy v. Colvin, 759 F.3d 811, 815-16 (7th Cir. 2014). The ALJ must consider factors like medication efficacy and side effects, daily activities,

treatment received, and precipitating pain factors. SSR 16-3p, No. SSA-2015-0055, 2017 WL 5180304, at *3 (Oct. 25, 2017). That said, the court will not disturb a subjective symptom evaluation that is logically based on specific findings and evidence. See Murphy, 759 F.3d at 815-16. Miguel first argues that the ALJ improperly considered his daily activities, including his ability to perform “chores around the building for the landlord and neighbors, cook, clean, [] sometimes take walks,” and “maintain his own hygiene

without assistance on a daily basis.” (R. 17, Pl.’s Br. at 14-16 (citing A.R. 24, 445).) He says that the ALJ failed to explain how his daily activities undercut his subjective allegations. (See id. at 15 (citing Jelenik v. Astrue, 662 F.3d 805, 812 (7th Cir. 2011).) The court disagrees. The ALJ discussed Miguel’s testimony that he experiences “chronic fatigue, shortness of breath, loss of strength, widespread joint pain, [and] diminished movement,” which he says prevent him from “walk[ing] farther than two to three blocks before needing to sit down, stand[ing] for extended periods, [and] squatting, kneeling, or climbing stairs.” (A.R. 27.) The ALJ also acknowledged Miguel’s allegations that his mental impairments severely restrict “his ability to

concentrate, retain information, maintain normal energy levels, interact appropriately with others, and complete tasks.” (Id.) However, when comparing Miguel’s symptom allegations with his ability to perform “a wide range of activities,” the ALJ concluded that “his physical and mental impairments [we]re not as severe as alleged.” (Id. at 34.) In so finding, the ALJ “examine[d] all of the evidence, including [Miguel’s]

daily activities, to assess whether testimony about the effects of his impairments was credible or exaggerated,” and found the latter was true here. Hahn v. Kijakazi, No. 22-1106, 2022 WL 6628832, at *2 (7th Cir. Oct. 11, 2022) (quotation and citations omitted). For example, the ALJ pointed to psychological CE Dr. Daniel Louis Friedman’s January 2020 findings that despite Miguel’s reports that he “spends most of his day watching television,” on evaluation Miguel “demonstrated appropriate attitude [] and behavior” and had “an adequately developed vocabulary,” even though

he “spoke in a direct abbreviated fashion.” (A.R. 27-28.) The ALJ further recited Dr. Friedman’s findings that Miguel had only “mild deficits in fund of information, immediate memory, and past memory,” and his “recent memory and judgment were within normal limits.” (Id. at 28.) Considering these findings along with Miguel’s ability to perform chores in his building, cook, clean, and take walks, the ALJ determined that Miguel’s daily activities suggest greater functioning than he alleged. (See id. at 27-28.) The court finds no patent error in the ALJ’s analysis here. Next Miguel complains that the ALJ erred by characterizing his treatment as

“sparse” and “conservative.” (R. 17, Pl.’s Br. at 15-16.) The ALJ noted the “absence of aggressive treatment” for Miguel’s physical impairments and cited to records from “[t]reating and examining sources” who observed “only slightly diminished muscle strength, range of motion, and overall neurologic functioning,” which she found inconsistent with Miguel’s subjective allegations. (A.R. 34.) The ALJ further indicated that Miguel’s “sparse mental health treatment was [] conservative in

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Miguel D. v. Frank Bisignano, Commissioner of Social Security, (N.D. Ill. 2026).

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