Nicki Jackson v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, M.D. Alabama
DecidedMarch 31, 2026
Docket2:24-cv-00619
StatusUnknown

This text of Nicki Jackson v. Frank Bisignano, Commissioner of Social Security (Nicki Jackson v. Frank Bisignano, Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nicki Jackson v. Frank Bisignano, Commissioner of Social Security, (M.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION ) NICKI JACKSON, ) ) Plaintiff, ) ) v. ) CASE NO. 2:24-cv-619-BL-JTA ) ) FRANK BISIGNANO, ) Commissioner of Social Security,

Defendant.

ORDER On March 9, 2026, the Magistrate Judge recommended that the court affirm the decision of the Commissioner of Social Security denying benefits to the Plaintiff. (Doc. 24). The Plaintiff filed objections, (doc. 25), and the Commissioner responded, (doc. 26). A district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). A district judge must “make a de novo determination of those portions of the [magistrate judge’s] report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1)(C); see also Fed. R. Civ. P. 72(b)(3) (“The district judge must determine de novo any part of the magistrate judge's disposition that has been properly objective to.”). A district court’s obligation to “make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made” requires a district judge to “give fresh consideration to those issues to which specific objection has been

made by a party.” United States v. Raddatz, 447 U.S. 667, 673, 675 (1980) (internal quotations and citations omitted) (emphasis in Raddatz). Specifically, the Plaintiff objects to the Magistrate Judge’s conclusion that the

ALJ did not commit reversible error by failing to address Plaintiff’s hearing testimony in his credibility determination. (Doc. 25 at 2).1 The Plaintiff argues that the Magistrate Judge’s finding that it is unclear whether the ALJ was referring only to the Plaintiff’s function reports because the ALJ “did not provide citations after

the summary of Plaintiff’s symptoms” is an “impermissible post-hoc rationalization.” (Doc. 25 at 3-4). The Plaintiff asserts that the ALJ’s citation to the Plaintiff’s function reports in Exhibits 4E and 9E forecloses “any inference that [the

ALJ] considered the hearing testimony.” (Doc. 25 at 4). Even if the ALJ referenced only Plaintiff’s function reports when describing her subjective symptoms, the court agrees with the Magistrate Judge that the ALJ did not err “because there is no requirement that the ALJ must reference specific

1 The Plaintiff did not object to the Magistrate Judge’s findings on the first issue regarding the Plaintiff’s RFC. On that issue, the Magistrate Judge concluded that “[b]ecause the hypothetical posed to the VE included a limitation to gradual and infrequent changes in the work setting, the ALJ’s omission of the adapting and managing limitation from Plaintiff’s RFC does not affect the ALJ’s ultimate conclusion that Plaintiff could perform jobs in the national economy.” (Doc. 24 at 8). The court agrees with the Magistrate Judge’s findings on this issue. hearing testimony in his opinion.” (Doc. 24 at 10). “The ALJ is not required to examine every piece of evidence in his opinion, so long as the decision does not broadly reject the claimant’s case and is sufficient for a reviewing court ‘to conclude

that the ALJ considered the claimant's medical condition as a whole.’” Brito v. Comm’r, Soc. Sec. Admin., 687 F. App’x 801, 804 (11th Cir. 2017) (quoting Mitchell v. Comm’r, Soc. Sec. Admin., 771 F.3d 780, 782 (11th Cir. 2017)). The ALJ “need

not cite particular phrases or formulations” when assessing a Plaintiff’s symptoms so long as the reviewing court can be satisfied that the ALJ assessed the Plaintiff’s full medical condition. Chatham v. Comm'r of Soc. Sec., 764 F. App’x 864, 868 (11th Cir. 2019) (internal quotation marks and citation omitted). “The ALJ must

only discuss enough evidence to demonstrate that [he] considered the claimant’s condition as a whole.” Thomas v. Comm'r of Soc. Sec., 497 F. App’x 916, 918–19 (11th Cir. 2012).

Here, the ALJ found that the claimant suffered from severe impairments of inflammatory arthritis, depression, anxiety, spine disorder, and obesity. (Doc. 14-2 at 26). The ALJ specifically stated that he “considered all symptoms and the extent to which these symptoms can reasonably be expected as consistent with the medical

evidence and other evidence, based on the requirements of 20 CFR 404.1529 and 416.929 and SSR 16-3p.” (Doc. 14-2 at 29); see Nance-Goble v. Saul, No. 4:20-cv- 00369-CLM, 2021 WL 2401178, at *3–5 (N.D. Ala. June 11, 2021) (finding the ALJ did not specifically mention the claimant’s relevant hearing testimony but stated he considered “all [her] symptoms” based upon §§ 404.1529, 416.929, and thus, did not improperly omit reference to the claimant’s testimony). The ALJ acknowledged that

the Plaintiff “complained of pain all over and stated that she is no longer able to use her hands, lift, walk, and move her arms and shoulders like she could in the past.” Doc. 14-2 at 29). As the Magistrate Judge noted, the ALJ “explained his credibility

determination, referencing medical records, objective medical imaging, physical examinations, prescribed medications, medical opinions, and prior administrative medical findings.” (Doc. 24 at 11 (citing Doc. 14-2 at 29-33)). The court agrees with the Magistrate Judge that “the ALJ’s decision is not a broad rejection of

Platiniff’s subjective complaints but rather shows the ALJ considered Plaintiff’s medical condition as a whole.” (Doc. 24 at 11). Thus, the court OVERRULES the Plaintiff’s objections on this issue.

The Plaintiff’s also objects to the ALJ’s finding that even if the ALJ erred in not citing the hearing testimony, that error was harmless. (Doc. 25 at 6). The Plaintiff argues that the “Magistrate Judge’s harmless error conclusion rests entirely on the premise that Plaintiff’s hearing testimony was ‘substantially similar’ to the

function reports in Exhibits 4E and 9E.” (Doc. 25 at 6). The Plaintiff asserts that a “thorough, side-by-side analysis” of those exhibits “reveals at least six discrete categories of functional limitation that were present in Plaintiff’s sworn testimony but absent—or materially more severe than—anything recorded in either function report.” (Doc. 25 at 6). The court is unpersuaded. The Plaintiff’s statement in her function report that she could not sit “to[o]

long” is substantially like her testimony that she could not “sit for [a] long period of time” and can sit only for “ten to 15 minutes” at a time. (Doc. 14-2 at 50, 57; Doc. 14-6 at 42, 44). Her testimony that she could stand and walk for “five to ten minutes”

is less restrictive than her statements in her function reports that she could walk a “few steps”, “10 steps,” or “5 feet” before she had to rest for 30 minutes or “hours” and that she could not stand “long” and for only “5 mins.” (Doc. 14-2 at 57; Doc. 14-6 at 25, 44, 47). The Plaintiff’s testimony that she could not straighten her arms

and “can’t bend [her elbows’ out straight sometimes from the inflammation” is similar to her statements in her function reports that she could not move her arms and shoulders and had issues reaching. (Doc. 14-2 at 51; Doc. 14-6 at 21, 25, 47).

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Related

United States v. Raddatz
447 U.S. 667 (Supreme Court, 1980)
Robert Thomas v. COmmissioner of Social Security
497 F. App'x 916 (Eleventh Circuit, 2012)

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Bluebook (online)
Nicki Jackson v. Frank Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nicki-jackson-v-frank-bisignano-commissioner-of-social-security-almd-2026.