Raquel Ramirez-Benitez v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, D. Puerto Rico
DecidedJanuary 15, 2026
Docket3:25-cv-01210
StatusUnknown

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

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Raquel Ramirez-Benitez v. Frank Bisignano, Commissioner of Social Security, (prd 2026).

Opinion

1 IN THE UNITED STATES DISTRICT COURT 2 FOR THE DISTRICT OF PUERTO RICO

4 RAQUEL RAMIREZ-BENITEZ,

5 Plaintiff,

6 CIVIL NO. 25-1210 (HRV) v. 7

8 FRANK BISIGNANO, Commissioner of Social Security, 9 10 Defendant.

11 OPINION AND ORDER1 12

13 Raquel Ramirez-Benitez (hereinafter “Ms. Ramirez” or “Plaintiff”), seeks review 14 of the final administrative decision of the Commissioner of Social Security (“the 15 Commissioner”) denying her claim for disability benefits under the Social Security Act 16 (“the Act”). She requests that the Commissioner’s decision be reversed and that the case 17 be remanded for further administrative proceedings. The Commissioner opposes, 18 19 arguing that the decision should be affirmed because it is based on substantial evidence. 20 I. LEGAL FRAMEWORK 21 A. Standard of Review 22 Pursuant to 42 U.S.C. § 405(g), any individual may obtain review of a final 23 decision of the Commissioner. Under said statutory provision, the Court is empowered 24 25 26 27 1 Camille A. González-Correa, a third-year law student at the Inter American University of Puerto Rico School of Law, provided significant assistance in the research and drafting of this Opinion and Order. 28 1 1 “to enter, upon the pleadings and transcript of the record, a judgment affirming, 2 modifying, or reversing the decision of the Commissioner….” Id. In addition, the statute 3 provides that if supported by substantial evidence, the findings of the Commissioner as 4 to any fact, shall be conclusive. Id. 5 A reviewing Court must uphold the decision of the Commissioner as long as the 6 7 Administrative Law Judge (“ALJ”) applied the correct legal principles, and the 8 determination is supported by substantial evidence. Seavey v. Barnhart, 276 F.3d 1, 9 9 (1st Cir. 2001). The scope of my review is, therefore, limited. I am tasked with 10 determining whether the ALJ employed the proper legal standards and focused facts 11 upon the proper quantum of evidence. See Ward v. Comm’r of Soc. Sec., 211 F.3d 652, 12 13 655 (1st Cir. 2000); see also Manso-Pizarro v. Sec’y of Health and Human Servs., 76 14 F.3d 15, 16 (1st Cir. 1996). 15 To meet the evidentiary benchmark, more than a scintilla of evidence is required. 16 Purdy v. Berryhill, 887 F.3d 7, 13 (1st Cir. 2018). But the threshold for evidentiary 17 sufficiency is not particularly high; if after looking at the existing administrative record, 18 19 the reviewing court is persuaded that it contains sufficient evidence to support the 20 Commissioner’s factual and legal determinations, the decision is bound to be affirmed. 21 See Biestek v. Berryhill, 587 U.S. 97, 102-03 (2019); see also Mosconas v. Saul, No. 19- 22 2049, 2020 WL 6255298, 2020 U.S. App. LEXIS 33755, at *2 (1st Cir. Sept. 15, 2020) 23 (citation omitted) (“Substantial evidence does not require preponderant evidence; it 24 merely requires evidence that reasonably supports the finding on the record as a whole.”) 25 26 Indeed, substantial evidence exists “if a reasonable mind, reviewing the evidence in the 27 record, could accept it as adequate to support [the] conclusion.” Irlanda-Ortiz v. Sec’y 28 2 1 of Health & Human Servs., 955 F.2d 765, 769 (1st Cir. 1991). The ALJ’s decision must be 2 reversed, however, if it was arrived at “by ignoring evidence, misapplying law, or judging 3 matters entrusted to experts.” Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999). 4 B. The Five-Step Sequential Evaluation Process 5 To be eligible for social security benefits, a claimant must demonstrate that he or 6 7 she is “disabled” within the meaning of the Act. Bowen v. Yuckert, 482 U.S. 137, 146, 8 (1987). The Act defines disability in pertinent part as the inability “to engage in any 9 substantial gainful activity by reason of any medically determinable physical or mental 10 impairment which has lasted or can be expected to last for a continuous period of not 11 less than twelve months.” 42 U.S.C. § 423(d)(1)(a), § 1382c(a)(3)(A). The impairment or 12 13 impairments must be severe enough that “he [or she] is not only unable to do his [or her] 14 previous work but cannot . . . engage in any other kind of substantial gainful work which 15 exists [in significant numbers] in the national economy….” Id., § 423(d)(2), § 16 1382c(a)(3)(B); see also 20 C.F.R. § 404.1520(a)(1). 17 The Commissioner follows a five-step evaluation process to determine disability. 18 19 See Mills v. Apfel, 244 F.3d 1, 2 (1st Cir. 2001); 20 C.F.R. § 404.1520(a). These steps must 20 be followed in order, and if a person is determined not to be disabled at any step, the 21 inquiry stops. Id. The Plaintiff has the burden of proof with respect to the first four steps 22 of the process. Freeman v. Barnhart, 274 F.3d 606, 608 (1st Cir. 2001). 23 Step one considers work activity, that is, whether the Plaintiff is currently “doing 24 substantial gainful activity.” 20 C.F.R. § 404.1520(a)(4)(i). If the person is, then she is 25 26 not disabled under the Act. Id. Step two asks whether the Plaintiff has a physical or 27 mental impairment—or a combination of impairments—that is severe and meets the 28 3 1 Act’s duration requirement. 20 C.F.R. § 404.1520(a)(4)(ii). Step three considers the 2 medical severity of the Plaintiff’s impairments. 20 C.F.R. § 404.1520(a)(4)(iii). At this 3 step, if Plaintiff is determined to have an impairment that meets or equals an impairment 4 listed in 20 C.F.R. pt. 404, Subpt. P., app. 1, and meets the duration requirements, she is 5 disabled. 20 C.F.R. § 404.1520(a)(4)(iii). On the other hand, if the Plaintiff is not found 6 7 to be disabled at this step, her Residual Functional Capacity (“RFC”) is assessed. 20 C.F.R. 8 § 404.1520(a)(4), (e). 9 Once the ALJ determines the RFC of the claimant, the inquiry proceeds to step 10 four. Step four compares the Plaintiff’s RFC to her past relevant work. 20 C.F.R. § 11 404.1520(a)(4)(iv). If the Plaintiff can still do her past relevant work, she is not disabled. 12 13 Id. Finally, at step five, the Plaintiff’s RFC is considered alongside her “age, education, 14 and work experience to see if [he or she] can make an adjustment to other work.” 20 15 C.F.R.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Ward v. Commissioner of Social Security
211 F.3d 652 (First Circuit, 2000)
Mills v. Social Security
244 F.3d 1 (First Circuit, 2001)
Seavey v. Social Security
276 F.3d 1 (First Circuit, 2001)
Freeman v. Massanari
274 F.3d 606 (First Circuit, 2001)
Lexington Management Corp. v. Lexington Capital Partners
10 F. Supp. 2d 271 (S.D. New York, 1998)
Purdy v. Berryhill
887 F.3d 7 (First Circuit, 2018)
Coskery v. Berryhill
892 F.3d 1 (First Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Sacilowski v. Saul
959 F.3d 431 (First Circuit, 2020)

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Raquel Ramirez-Benitez v. Frank Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/raquel-ramirez-benitez-v-frank-bisignano-commissioner-of-social-security-prd-2026.