Sheresa Exum v. Frank Bisgnano, Commissioner, Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedNovember 25, 2025
Docket3:25-cv-00118
StatusUnknown

This text of Sheresa Exum v. Frank Bisgnano, Commissioner, Social Security Administration (Sheresa Exum v. Frank Bisgnano, Commissioner, Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheresa Exum v. Frank Bisgnano, Commissioner, Social Security Administration, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

SHERESA EXUM PLAINTIFF

v. 3:25-cv-00118-JM-JJV

FRANK BISGNANO, Commissioner, Social Security Administration, DEFENDANT

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION

INSTRUCTIONS

This recommended disposition has been submitted to United States District Judge James M. Moody Jr. The parties may file specific objections to these findings and recommendations and must provide the factual or legal basis for each objection. The objections must be filed with the Clerk no later than fourteen (14) days from the date of the findings and recommendations. A copy must be served on the opposing party. The district judge, even in the absence of objections, may reject these proposed findings and recommendations in whole or in part. RECOMMENDED DISPOSITION Plaintiff, Sheresa Exum, has appealed the final decision of the Commissioner of the Social Security Administration to deny her claim for disability insurance benefits. The Administrative Law Judge (ALJ) concluded Plaintiff had not been under a disability within the meaning of the Social Security Act, because Ms. Exum could perform her past relevant work despite her impairments. (Tr. 16-24.) This review function is extremely limited. A court’s function on review is to determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole and to analyze whether Plaintiff was denied benefits due to legal error. Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997); see also, 42 U.S.C. § 405(g). Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Richardson v. Perales, 402 U.S. 389, 401 (1971); Reynolds v. Chater, 82 F.3d 254, 257 (8th Cir. 1996). In assessing the substantiality of the evidence, courts must consider evidence that detracts from the Commissioner’s decision as well as evidence that supports it; a court may not, however,

reverse the Commissioner’s decision merely because substantial evidence would have supported an opposite decision. Woolf v. Shalala, 3 F.3d 1210, 1213 (8th Cir. 1993). The history of the administrative proceedings and the statement of facts relevant to this decision are contained in the respective briefs and are not in serious dispute. Therefore, they will not be repeated in this opinion except as necessary. After careful review of the pleadings and evidence in this case, I find the Commissioner’s decision is supported by substantial evidence and recommend that Plaintiff’s Complaint be DISMISSED. Plaintiff was sixty-two years old at the time of the administrative hearing. (Tr. 37.) Ms. Exum is a college graduate, (Tr. 220), and has past relevant work as a controller. (Tr. 23.) She

has a strong work history. (Tr. 57.) The ALJ1 first found Ms. Exum had not engaged in substantial gainful activity since her alleged onset date of December 1, 2019, through her date of last insured of December 31,2019. (Tr. 18.) She has “severe” impairments in the form of “chronic ischemic heart disease, diabetes

1 The ALJ followed the required sequential analysis to determine: (1) whether the claimant was engaged in substantial gainful activity; (2) if not, whether the claimant had a severe impairment; (3) if so, whether the impairment (or combination of impairments) met or equaled a listed impairment; and (4) if not, whether the impairment (or combination of impairments) prevented the claimant from performing past relevant work; and (5) if so, whether the impairment (or combination of impairments) prevented the claimant from performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 416.920(a)-(g) and 404.1520(a)-(g). mellitus type II, congestive heart failure, atrial fibrillation, aortic aneurysm, bradycardia, thyroid problems, high cholesterol, and obesity.” (Id.) The ALJ further found Ms. Exum did not have an impairment or combination of impairments meeting or equaling an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1.2 (Tr. 20-21.) The ALJ determined Ms. Exum had the residual functional capacity (RFC) to perform a

slightly reduced range of light work. (Tr. 21.) The ALJ utilized the services of a vocational expert to determine if jobs existed that Plaintiff could perform despite her impairments. (Tr. 59-61.) Based in part on the testimony of the vocational expert, the ALJ determined Plaintiff could perform her past work as a controller - despite her limitations. (Tr. 23-24.) Accordingly, the ALJ determined Ms. Exum was not disabled. (Tr. 24.) The Appeals Council denied Plaintiff’s request for a review of the ALJ’s decision, making his decision the final decision of the Commissioner. (Tr. 4-8.) Plaintiff filed the instant Complaint initiating this appeal. (Doc. No. 1.) In support of her Complaint, Plaintiff argues that the ALJ’s RFC assessment failed to

consider her mental limitations, dizziness, and light sensitivity. (Doc. No. 5 at 13-21.) With regard to her mental limitations, Plaintiff argues: As a result of a combination of the Plaintiff’s severe impairments of “chronic ischemic heart disease, diabetes mellitus type II, congestive heart failure, atrial fibrillation, aortic aneurysm, bradycardia, thyroid problems, high cholesterol, and obesity” (Tr. 18) and non-severe impairments of “depressive disorder, bipolar disorder, anxiety disorder” (Tr. 19), the ALJ decided the Plaintiff has mild limitations in the four broad functionals areas known as the “paragraph B” criteria, which include the ability to understand, remember, or apply information, the ability to interact with others, the ability to concentrate, persist, or maintain pace, and the ability to adapt or manage oneself. (Tr. 19). The ALJ is “still required to consider [even mild mental limitations] when evaluating [the claimant]’s RFC.” [Citation omitted.]

2 20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526. (Doc. No. 5 at 17.)

Plaintiff’s argument is misplaced. The ALJ’s Step Two “paragraph B” findings are distinct from the Step Four RFC findings. And the ALJ specifically pointed this out in his opinion when he said, “The limitations identified in the “paragraph B” criteria are not a residual functional capacity assessment but are used to rate the severity of mental impairments at steps 2 and 3 of the sequential evaluation process. The mental residual functional capacity assessment used at steps 4 and 5 of the sequential evaluation process requires a more detailed assessment.” (Tr. 19.) So, contrary to Plaintiff’s argument, the ALJ was not required to include mental limitations in his RFC determination based upon his “paragraph B” findings. As the United States Court of Appeals for the Eighth Circuit has said, “As a practical matter, however, the different steps serve distinct purposes, the degrees of precision required at each step differ, and our deferential standard of review precludes us from labeling findings as inconsistent if they can be harmonized. See Lacroix v.

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Sheresa Exum v. Frank Bisgnano, Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheresa-exum-v-frank-bisgnano-commissioner-social-security-ared-2025.