Rito L. v. Frank Bisignano, Commissioner of Social Security

CourtDistrict Court, E.D. Washington
DecidedJanuary 16, 2026
Docket1:25-cv-03078
StatusUnknown

This text of Rito L. v. Frank Bisignano, Commissioner of Social Security (Rito L. v. Frank Bisignano, Commissioner of Social Security) 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
Rito L. v. Frank Bisignano, Commissioner of Social Security, (E.D. Wash. 2026).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Jan 16, 2026

SEAN F. MCAVOY, CLERK 4

7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 8

9 RITO L.,1 NO: 1:25-cv-03078-RLP 10 Plaintiff, v. 11 ORDER REVERSING AND FRANK BISIGNANO, REMANDING THE COMMISSIONER’S 12 COMMISSIONER OF SOCIAL DECISION FOR FURTHER SECURITY, ADMINISTRATIVE PROCEEDINGS 13

Defendant. 14

15 BEFORE THE COURT is an appeal from an Administrative Law Judge 16 (ALJ) final decision denying disability benefits under Title II of the Social Security 17 Act. The Court considered the matter without oral argument. 18 19

20 1 The Court identifies a plaintiff in a social security case only by the first

name and last initial in order to protect privacy. See LCivR 5.2(c). 1 The parties agree the ALJ committed reversible error by failing to include 2 Mr. L’s use of a cane at Step Four. However, they dispute the applicable remedy. 3 For the reasons set forth below, the Court finds that the case should be remanded to 4 the ALJ for further proceedings in keeping with this opinion.

5 BACKGROUND 6 Mr. L. was 43 years old at the alleged onset date of April 13, 2022. The 7 highest grade of education he has completed is the tenth grade. Mr. L. was

8 employed from January 2003 through December 2007; from January 2008 to 9 December 2017; from January 2020 to August 2020; and from September 2021 to 10 April 2022. 11 Mr. L. alleges that on April 12, 2022, he slipped on railroad tracks outside his

12 former workplace and has been unable to work since. He filed an application for 13 disability benefits under Title II of the Social Security Act, alleging onset on April 14 13, 2022. His claim was denied initially and upon reconsideration. He thereafter

15 requested a hearing pursuant to 20 C.F.R. § 404.929, which was held via telephone 16 conference on January 11, 2024. On April 29, 2024, the ALJ issued an unfavorable 17 decision, Tr. 19-31, and the Appeals Council denied review. Tr. 1-6. The matter is 18 now before the Court pursuant to 42 U.S.C. § 405(g).

19 STANDARD OF REVIEW 20 This Court’s review of a final decision of the Commissioner of Social Security 1 is governed by 42 U.S.C. § 405(g). The scope of review is limited; the 2 Commissioner’s decision will be disturbed “only if it is not supported by substantial 3 evidence or is based on legal error.” Hill v. Astrue, 698 F.3d 1153, 1158 (9th Cir. 4 2012). If the evidence in the record “is susceptible to more than one

5 rational interpretation, [the Court] must uphold the ALJ’s findings if they are 6 supported by inferences reasonably drawn from the record.” Molina v. Astrue, 674 7 F.3d 1104, 1111 (9th Cir. 2012).

8 Further, a district court “may not reverse an ALJ’s decision on account of an 9 error that is harmless.” Id. An error is harmless “where it is inconsequential to the 10 [ALJ’s] ultimate nondisability determination.” Id. at 1115 (quotation and citation 11 omitted). The party appealing the ALJ’s decision generally bears the burden of

12 establishing that it was harmed. Shinseki v. Sanders, 556 U.S. 396, 409-10 (2009). 13 FIVE-STEP EVALUATION PROCESS 14 A claimant must satisfy two conditions to be considered “disabled” within the

15 meaning of the Social Security Act. First, the claimant must be “unable to engage in 16 any substantial gainful activity by reason of any medically determinable physical or 17 mental impairment which can be expected to result in death or which has lasted or 18 can be expected to last for a continuous period of not less than twelve months.” 42

19 U.S.C. § 423(d)(1)(A). Second, the claimant’s impairment must be “of such severity 20 that he is not only unable to do [his or her] previous work[,] but cannot, considering 1 [his or her] age, education, and work experience, engage in any other kind of 2 substantial gainful work which exists in the national economy.” 42 U.S.C. § 3 423(d)(2)(A). 4 The Commissioner has established a five-step sequential analysis to determine

5 whether a claimant satisfies the above criteria. See 20 C.F.R. § 404.1520(a)(4)(i)-(v). 6 At step one, if the claimant is engaged in “substantial gainful activity,” the 7 Commissioner must find that the claimant is not disabled. 20 C.F.R. § 404.1520. At

8 step two, the Commissioner considers the severity of the claimant’s impairment. 20 9 C.F.R. § 404.1520(a)(4)(ii). If the claimant suffers from “any impairment or 10 combination of impairments which significantly limits [his or her] physical or 11 mental ability to do basic work activities,” the analysis proceeds to step three. 20

12 C.F.R. § 404.1520(c). At step three, the Commissioner compares the claimant’s 13 impairment to severe impairments recognized by the Commissioner to be so severe 14 as to preclude a person from engaging in substantial gainful activity. 20 C.F.R. §

15 404.1520(a)(4)(iii). 16 If the severity of the claimant’s impairment does not meet or exceed the 17 severity of the enumerated impairments, the Commissioner must assess the 18 claimant’s residual functional capacity (RFC), which is the claimant’s ability to

19 perform physical and mental work activities on a sustained basis despite his or her 20 limitations, 20 C.F.R. § 404.1545(a)(1). 1 At step four, the Commissioner considers whether, in view of the claimant’s 2 RFC, the claimant is capable of performing work that he or she has performed in the 3 past (past relevant work). 20 C.F.R. § 404.1520(a)(4)(iv). If not, 4 the analysis proceeds to step five and the Commissioner considers whether, in view

5 of the claimant’s RFC, the claimant is capable of performing other work in the 6 national economy. 20 C.F.R. § 404.1520(a)(4)(v). 7 The claimant bears the burden of proof at steps one through four above.

8 Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999). If the analysis proceeds to 9 step five, the burden shifts to the Commissioner to establish that (1) the claimant is 10 capable of performing other work; and (2) such work “exists in significant numbers 11 in the national economy.” 20 C.F.R. § 404.1560(c)(2); Beltran v. Astrue, 700 F.3d

12 386, 389 (9th Cir. 2012). 13 ALJ’S FINDINGS 14 At step one, the ALJ found that Mr. L. had not engaged in substantial gainful

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