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

District Court, E.D. Washington·Decided August 5, 2026·No. 4:26-cv-05010·Unknown

Opinion

Aug 05, 2026 SEAN F. MCAVOY, CLERK

MIGUEL L.,1 No. 4:26-CV-05010-MKD Plaintiff, ORDER REVERSING AND REMANDING DECISION OF v. COMMISSIONER FRANK BISIGNANO, ECF Nos. 12, 16 COMMISSIONER OF SOCIAL Defendant. Before the Court are the parties’ briefs. ECF Nos. 12, 16. D. James Tree represents Plaintiff. Special Assistant United States Attorney David Burdett represents Defendant. The Court, having reviewed the administrative record and the parties’ briefing, is fully informed. For the reasons discussed below, the Court

1 To protect the privacy of plaintiffs in social security cases, the Court identifies

them by only their first names and the initial of their last names. See LCivR 5.2(c). reverses the Commissioner’s decision and remands the case for the immediate calculation and award of benefits.

On September 1, 2017, Plaintiff filed an application for supplemental security income under Title XVI of the Social Security Act, alleging disability

beginning September 1, 2017. Tr. 139, 252-56. The application was denied initially and on reconsideration. Tr. 14, 139-75. Plaintiff appeared before an administrative law judge (ALJ) for a hearing on January 28, 2020. Tr. 73-118. On February 12, 2020, the ALJ denied Plaintiff’s claim. Tr. 12-35. This Court

remanded the matter on October 25, 2021. Tr. 1698-1704. The ALJ held another hearing on March 8, 2023. Tr. 1630-67. On April 19, 2023, the ALJ issued a partially favorable decision finding Plaintiff disabled beginning March 1, 2022, but

not before that date. Tr. 6319-53. This Court again remanded the matter on October 27, 2023. Tr. 6354-62. The ALJ held a third hearing on November 12, 2025. Tr. 6296-6318. On November 19, 2025, the ALJ issued a partially favorable decision finding Plaintiff disabled beginning May 27, 2021, but not

before that date. Tr. 6246-82. Plaintiff appealed this final decision on January 21, 2026. ECF No. 1. The Court has jurisdiction over this case pursuant to 42 U.S.C. § 1383(c)(3).

A district court’s review of a final decision of the Commissioner of Social

Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is limited; the Commissioner’s decision will be disturbed “only if it is not supported by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153,

1158 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a reasonable mind might accept as adequate to support a conclusion.” Id. at 1159 (quotation and citation omitted). Stated differently, substantial evidence equates to “more than a mere scintilla[,] but less than a preponderance.” Id. (quotation and

citation omitted). In determining whether the standard has been satisfied, a reviewing court must consider the entire record as a whole rather than searching for supporting evidence in isolation. Id.

In reviewing a denial of benefits, a district court may not substitute its judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one rational interpretation, [the court] must uphold the ALJ’s findings if they are

supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 F.3d 1104, 1111 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. §§ 404.1502(a), 416.902(a). Further, a district court “may not reverse an ALJ’s

decision on account of an error that is harmless.” Id. An error is harmless “where it is inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1115 (quotation and citation omitted). The party appealing the ALJ’s decision

generally bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 396, 409-10 (2009).

A claimant must satisfy two conditions to be considered “disabled” within the meaning of the Social Security Act. First, the claimant must be “unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which

has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). Second, the claimant’s impairment must be “of such severity that he is not only unable to do his previous

work[,] but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy.” 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B). The Commissioner has established a five-step sequential analysis to

determine whether a claimant satisfies the above criteria. See 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 416.920(a)(4)(i)-(v). At step one, the Commissioner considers the claimant’s work activity. 20 C.F.R. §§ 404.1520(a)(4)(i),

416.920(a)(4)(i). If the claimant is engaged in “substantial gainful activity,” the Commissioner must find that the claimant is not disabled. 20 C.F.R. §§ 404.1520(b), 416.920(b).

If the claimant is not engaged in substantial gainful activity, the analysis proceeds to step two. At this step, the Commissioner considers the severity of the claimant’s impairment. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the

claimant suffers from “any impairment or combination of impairments which significantly limits [his or her] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant’s impairment does not satisfy this severity threshold,

however, the Commissioner must find that the claimant is not disabled. Id. At step three, the Commissioner compares the claimant’s impairment to severe impairments recognized by the Commissioner to be so severe as to preclude

a person from engaging in substantial gainful activity. 20 C.F.R. §§ 404.1520(a)(4)(iii), 416.920(a)(4)(iii). If the impairment is as severe or more severe than one of the enumerated impairments, the Commissioner must find the claimant disabled and award benefits. 20 C.F.R. §§ 404.1520(d), 416.920(d).

If the severity of the claimant’s impairment does not meet or exceed the severity of the enumerated impairments, the Commissioner must pause to assess the claimant’s “residual functional capacity.” Residual functional capacity (RFC),

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Miguel L. v. Frank Bisignano, Commissioner of Social Security, (E.D. Wash. 2026).

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