Richardson v. Bisignano

CourtDistrict Court, E.D. North Carolina
DecidedJuly 1, 2025
Docket5:24-cv-00280
StatusUnknown

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

Bluebook
Richardson v. Bisignano, (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION No. 5:24-CV-280-FL LANCE SALVAS RICHARDSON, Plaintiff/Claimant, V. MEMORANDUM AND RECOMMENDATION FRANK J. BISIGNANO, Commissioner of Social Security, Defendant.

This matter is before the court on the parties’ briefs filed pursuant to the Supplemental Rules for Social Security Actions. [DE-15,' -18, -19]. Claimant Lance Richardson (“Claimant”) filed this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3), seeking judicial review of the denial of his application for Supplemental Security Income (“SSI”) payments. Briefing is complete, and the matter is ripe for adjudication. Having carefully reviewed the administrative record and the briefs submitted by the parties, it is recommended that the final decision of the Commissioner be affirmed. I. STATEMENT OF THE CASE Claimant was previously awarded Child Disability Benefits, which were continued after a continuing disability review (“CDR”) until his benefits were terminated in April 2021, due to his incarceration for a period exceeding twelve months. (R. 85, 537-39). Claimant protectively filed a new application for SSI on October 4, 2021, alleging disability beginning November 1, 1993.

| Claimant filed a motion pursuant to Fed. R. Civ. P. 56(c), [DE-14], and a memorandum in support, [DE-15], which the court construes as Claimant’s brief pursuant to Rule 6 of the Supplemental Rules for Social Security Actions.

(R. 23, 149-55). The claim was denied initially and upon reconsideration. (R. 23, 84-103). A hearing before the Administrative Law Judge (“ALJ”) was held on March 22, 2023, at which Claimant, proceeding without a representative, and a vocational expert (“VE”) appeared and testified. (R. 43-70). On May 11, 2023, the ALJ issued a decision denying Claimant’s request for benefits. (R. 20-42). On March 15, 2024, the Appeals Council denied Claimant’s request for review. (R. 1-7). Claimant then filed a complaint in this court seeking review of the now-final administrative decision. II. STANDARD OF REVIEW The scope of judicial review of a final agency decision regarding disability benefits under the Social Security Act (“Act”), 42 U.S.C. § 301 et seg., is limited to determining whether substantial evidence supports the Commissioner’s factual findings and whether the decision was reached through the application of the correct legal standards. See Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). “The findings of the Commissioner . . . as to any fact, if supported by substantial evidence, shall be conclusive ... .” 42 U.S.C. § 405(g). Substantial evidence is “evidence which a reasoning mind would accept as sufficient to support a particular conclusion.” Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966). While substantial evidence is not a “large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988), it is “more than a mere scintilla .. . and somewhat less than a preponderance.” Laws, 368 F.2d at 642. “In reviewing for substantial evidence, [the court should not] undertake to re-weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996), superseded by regulation on other grounds, 20 C.F.R. § 416.927(d)(2)). Rather, in conducting the “substantial evidence” inquiry, the court’s review is

limited to whether the ALJ analyzed the relevant evidence and sufficiently explained his or her findings and rationale in crediting the evidence. Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438, 439-40 (4th Cir. 1997). Ill. DISABILITY EVALUATION PROCESS The disability determination is based on a five-step sequential evaluation process as set forth in 20 C.F.R. § 416.920 under which the ALJ is to evaluate a claim: The claimant (1) must not be engaged in “substantial gainful activity,” i.e., currently working; and (2) must have a “severe” impairment that (3) meets or exceeds [in severity] the “listings” of specified impairments, or is otherwise incapacitating to the extent that the claimant does not possess the residual functional capacity to (4) perform . . . past work or (5) any other work. Albright v. Comm’r of the SSA, 174 F.3d 473, 475 n.2 (4th Cir. 1999). “If an applicant’s claim fails at any step of the process, the ALJ need not advance to the subsequent steps.” Pass v. Chater, 65 F.3d 1200, 1203 (4th Cir. 1995) (citation omitted). The burden of proof and production during the first four steps of the inquiry rests on the claimant. /d At the fifth step, the burden shifts to the ALJ to show that other work exists in the national economy which the claimant can perform. /d. When assessing the severity of mental impairments, the ALJ must do so in accordance with the “special technique” described in 20 C.F.R. § 416.920a(b)-(c). This regulatory scheme identifies four broad functional areas in which the ALJ rates the degree of functional limitation resulting from a claimant’s mental impairment(s): understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting or managing oneself. Jd. § 416.920a(c)(3). The ALJ is required to incorporate into his written decision pertinent findings and conclusions based on the “special technique.” /d. § 416.920a(e)(3). IV. ALJ’S FINDINGS Applying the above-described sequential evaluation process, the ALJ found Claimant “not

disabled” as defined in the Act. At step one, the ALJ found Claimant had not engaged in substantial gainful employment since October 4, 2021, the application date. (R. 25). Next, the ALJ determined Claimant had the severe impairments of chronic obstructive pulmonary disease, essential hypertension, obesity, intellectual disorder, attention deficit hyperactivity disorder, and depression, and the nonsevere impairments of alcohol use disorder and gastroesophageal reflux disease. /d. At step three, the ALJ concluded Claimant’s impairments were not severe enough, either individually or in combination, to meet or medically equal one of the listed impairments in 20 C.F.R.

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Richardson v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richardson-v-bisignano-nced-2025.