Neifert v. Bisignano

CourtDistrict Court, E.D. Washington
DecidedAugust 22, 2025
Docket1:24-cv-03084
StatusUnknown

This text of Neifert v. Bisignano (Neifert v. Bisignano) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Neifert v. Bisignano, (E.D. Wash. 2025).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Aug 22, 2025 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 MELVIN N.,1 No. 1:24-CV-03084-MKD

8 Plaintiff, ORDER AFFIRMING DECISION OF COMMISSIONER 9 v. ECF Nos. 8, 9 10 FRANK BISIGNANO, COMMISSIONER OF SOCIAL 11 SECURITY,2

12 Defendant. 13 14

15 1 To protect the privacy of plaintiffs in social security cases, the Court identifies 16 them by only their first names and the initial of their last names. See LCivR 5.2(c). 17 2 Frank Bisignano became the Commissioner of Social Security on May 7, 18 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank 19 Bisignano is substituted for Martin O’Malley as the defendant in this suit. No 20 further action need be taken to continue this suit. See 42 U.S.C. § 405(g). 1 Before the Court are the parties’ briefs. ECF Nos. 8, 9. The Court, having 2 reviewed the administrative record and the parties’ briefing, is fully informed. For

3 the reasons discussed below, the Court affirms the Commissioner’s decision. 4 JURISDICTION 5 Plaintiff filed an application for benefits on April 17, 2020, alleging

6 disability beginning October 1, 2018. Tr. 426-32. The application was denied 7 initially and upon reconsideration. Tr. 204-34. An Administrative Law Judge 8 (ALJ) held a hearing on July 16, 2021. Tr. 62-89. The ALJ issued an unfavorable 9 decision on July 28, 2021. Tr. 235-54. The Appeals Council remanded the matter

10 on November 4, 2022. Tr. 255-61. A different ALJ held a hearing on October 24, 11 2023, Tr. 90-127, and issued an unfavorable decision on November 28, 2023. Tr. 12 18-37. The Appeals Council denied review on April 19, 2024. Tr. 1-7. Plaintiff

13 appealed this final decision of the Commissioner on June 5, 2024. ECF No. 1. 14 The Court has jurisdiction over this case pursuant to 42 U.S.C. § 405(g). 15 STANDARD OF REVIEW 16 A district court’s review of a final decision of the Commissioner of Social

17 Security is governed by 42 U.S.C. § 405(g). The scope of review under § 405(g) is 18 limited; the Commissioner’s decision will be disturbed “only if it is not supported 19 by substantial evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153,

20 1158 (9th Cir. 2012). “Substantial evidence” means “relevant evidence that a 1 reasonable mind might accept as adequate to support a conclusion.” Id. at 1159 2 (quotation and citation omitted). Stated differently, substantial evidence equates to

3 “more than a mere scintilla[,] but less than a preponderance.” Id. (quotation and 4 citation omitted). In determining whether the standard has been satisfied, a 5 reviewing court must consider the entire record as a whole rather than searching

6 for supporting evidence in isolation. Id. 7 In reviewing a denial of benefits, a district court may not substitute its 8 judgment for that of the Commissioner. Edlund v. Massanari, 253 F.3d 1152, 9 1156 (9th Cir. 2001). If the evidence in the record “is susceptible to more than one

10 rational interpretation, [the court] must uphold the ALJ’s findings if they are 11 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 12 F.3d 1104, 1111 (9th Cir. 2012), superseded on other grounds by 20 C.F.R. §

13 404.1502(a). Further, a district court “may not reverse an ALJ’s decision on 14 account of an error that is harmless.” Id. An error is harmless “where it is 15 inconsequential to the [ALJ’s] ultimate nondisability determination.” Id. at 1115 16 (quotation and citation omitted). The party appealing the ALJ’s decision generally

17 bears the burden of establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 18 396, 409-10 (2009). 19

20 1 FIVE-STEP EVALUATION PROCESS 2 A claimant must satisfy two conditions to be considered “disabled” within

3 the meaning of the Social Security Act. First, the claimant must be “unable to 4 engage in any substantial gainful activity by reason of any medically determinable 5 physical or mental impairment which can be expected to result in death or which

6 has lasted or can be expected to last for a continuous period of not less than twelve 7 months.” 42 U.S.C. § 423(d)(1)(A). Second, the claimant’s impairment must be 8 “of such severity that he is not only unable to do his previous work[,] but cannot, 9 considering his age, education, and work experience, engage in any other kind of

10 substantial gainful work which exists in the national economy.” 42 U.S.C. § 11 423(d)(2)(A). 12 The Commissioner has established a five-step sequential analysis to

13 determine whether a claimant satisfies the above criteria. See 20 C.F.R. § 14 404.1520(a)(4)(i)-(v). At step one, the Commissioner considers the claimant’s 15 work activity. 20 C.F.R. § 404.1520(a)(4)(i). If the claimant is engaged in 16 “substantial gainful activity,” the Commissioner must find that the claimant is not

17 disabled. 20 C.F.R. § 404.1520(b). 18 If the claimant is not engaged in substantial gainful activity, the analysis 19 proceeds to step two. At this step, the Commissioner considers the severity of the

20 claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers 1 from “any impairment or combination of impairments which significantly limits 2 [his or her] physical or mental ability to do basic work activities,” the analysis

3 proceeds to step three. 20 C.F.R. § 404.1520(c). If the claimant’s impairment 4 does not satisfy this severity threshold, however, the Commissioner must find that 5 the claimant is not disabled. Id.

6 At step three, the Commissioner compares the claimant’s impairment to 7 severe impairments recognized by the Commissioner to be so severe as to preclude 8 a person from engaging in substantial gainful activity. 20 C.F.R. § 9 404.1520(a)(4)(iii). If the impairment is as severe or more severe than one of the

10 enumerated impairments, the Commissioner must find the claimant disabled and 11 award benefits. 20 C.F.R. § 404.1520(d). 12 If the severity of the claimant’s impairment does not meet or exceed the

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