Paula Simmons v. Frank Bisignano, Commissioner of Social Security

District Court, N.D. Alabama·Decided July 16, 2026·No. 7:25-cv-00711·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION PAULA SIMMONS, ) ) Plaintiff, ) ) v. ) 7:25-cv-711-EGL ) FRANK BISIGNANO, ) Commissioner of ) Social Security, ) ) Defendant. ) MEMORANDUM OPINION

Paula Simmons seeks judicial review of the Commissioner of Social Security’s denial of her applications for disability insurance benefits and supplemental security income. See Doc. 9 at 1. Simmons argues that substantial evidence does not support the Administrative Law Judge’s (ALJ) residual functional capacity determination because the ALJ failed to include, or otherwise mischaracterized, limitations identified by her treating chiropractor, an examining physician, and an examining specialist. Id. at 2. After careful review of the administrative record and the parties’ briefs, the Court AFFIRMS the Commissioner’s decision. BACKGROUND A. Procedural Background

Simmons filed applications for a period of disability, disability insurance benefits, and supplemental security income on January 21, 2022, alleging that her disability began on November 30, 2021. See Doc. 9 at 1; Doc. 12 at 1. The agency

denied her claims initially on October 27, 2022, Doc. 6-5 at 28-37, and again on reconsideration on September 1, 2023, id. at 40-47. Simmons requested a hearing, and, on March 13, 2024, she appeared with counsel and testified by telephone before an ALJ; an impartial vocational expert also testified. Doc. 6-3 at 37-58. On May 21,

2024, the ALJ issued a decision finding that Simmons was not disabled. Id. at 9-24. On April 21, 2025, the Appeals Council denied review, making the ALJ’s decision the final decision of the Commissioner. Id. at 1-8. Simmons then filed this

action. Doc. 1. She has exhausted her administrative remedies, and the Court has jurisdiction under 42 U.S.C. §§ 405(g), 1383(c)(3). B. Factual Background Simmons alleged disability based on a condition affecting both legs, a back

condition, depression, anxiety, chronic fatigue, and morbid obesity. Doc. 6-8 at 6. She was fifty-four years old on the alleged onset date, has an eleventh-grade education, and has past work in customer service and as a cook. Id. at 2, 7; Doc. 6-

3 at 47-53. At the hearing, Simmons testified that she must use a rollator to walk, that injections relieve her pain for only a few days, and that the more active she is, the

more she hurts. Doc. 6-3 at 38-47. She estimated that she could walk 100 feet with her walker, stand for up to ten minutes, and sit for about ten minutes; and she stated that she elevates her feet twice a day to prevent swelling. Id. at 44-45. She described

significant sensitivity in her legs from vein problems and said she tried to do chores but cannot help much. Id. at 45-48. In her function reports, she alleged that she cannot stand for long periods of time because of swelling, can walk only short distances, used a cane, and could lift about five pounds. Doc. 6-8 at 49-52.

ALJ DECISION To determine whether a claimant is disabled, an ALJ applies a five-step sequential evaluation process, asking whether the claimant (1) is engaged in

substantial gainful activity; (2) has a severe impairment or combination of impairments; (3) has an impairment that meets or equals the severity of a listed impairment; (4) can perform any past relevant work; and, if not, (5) can adjust to other work that exists in significant numbers in the national economy. Winschel v.

Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). At step one, the ALJ found that Simmons had not engaged in substantial gainful activity since November 30, 2021. Doc. 6-3 at 14. At step two, the ALJ found

that Simmons had two severe impairments: morbid obesity and varicose veins of the bilateral lower extremity. Id. At step three, the ALJ concluded that none of Simmons’s impairments, alone or in combination, met or medically equaled a listed

impairment. Id. at 15. The ALJ then assessed Simmons’s residual functional capacity (RFC). Applying the two-step framework of 20 C.F.R. §§ 404.1529 and 416.929 and Social

Security Ruling 16-3p, the ALJ found that Simmons’s impairments could reasonably be expected to cause some of her alleged symptoms, but that her statements about the intensity, persistence, and limiting effects of those symptoms were “not entirely consistent with the medical evidence and other evidence in the record.” Doc. 6-3 at

15-16. After considering the entire record, the ALJ found that Simmons could perform light work, except that she can frequently climb ramps and stairs, but should avoid ladders, ropes, and scaffolds. Id. at 15-18.

At step four, relying on the vocational expert’s testimony, the ALJ found that Simmons could perform her past relevant work in customer service (DOT 279.357- 054, light, SVP 3), both as she actually performed it and as it is generally performed. Id. at 18-19. The ALJ noted that Simmons had also worked as a cook (DOT 313.361-

014, medium, SVP 7), but the vocational expert testified that the RFC precludes that job. Id. at 19. The ALJ therefore concluded that Simmons had not been disabled under the Social Security Act from November 30, 2021, through the date of the

decision. Id. STANDARD OF REVIEW Judicial review under the Social Security Act is narrow. The Court asks only

whether substantial evidence supports the Commissioner’s decision and whether it rests on the correct legal standards. Winschel, 631 F.3d at 1178. “[W]hatever the meaning of ‘substantial’ in other contexts,” in the context of judicial review of social

security decisions, the threshold “is not high.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). Substantial evidence is “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Henry v. Comm’r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015).

Under this standard, the Court may not decide the facts anew, reweigh the evidence, or substitute its judgment for the Commissioner’s. Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005). Even if the evidence preponderates against the

Commissioner’s findings, the Court must affirm if substantial evidence supports them. Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155, 1158-59 (11th Cir. 2004). DISCUSSION Simmons raises one claim: that substantial evidence does not support the

ALJ’s RFC determination because it “failed to include the limitations identified by the treating chiropractor, the examining physician, and the examining specialist, whose opinion was mischaracterized by the ALJ.” Doc. 9 at 2. Those sources are,

respectively, chiropractor Tammy Moore, D.C.; consultative examiner Dr. Remona Peterson; and Dr. Marc Passman of the UAB Vein Clinic. Id. at 6-12. The Court first explains why the RFC rests on substantial evidence and then addresses each of

Simmons’s objections. None warrants reversal. I. RFC Determination A claimant’s RFC is the most she can do in a work setting despite her

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Paula Simmons v. Frank Bisignano, Commissioner of Social Security, (N.D. Ala. 2026).

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