Somers v. Bisignano

CourtDistrict Court, D. Nevada
DecidedJune 25, 2025
Docket2:24-cv-01594
StatusUnknown

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

Bluebook
Somers v. Bisignano, (D. Nev. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 7 ROBIN S., Case No. 2:24-cv-01594-NJK

8 Plaintiff, Order 9 v. 10 FRANK BISIGNANO, 11 Defendant. 12 This case involves judicial review of administrative action by the Commissioner of Social 13 Security (“Commissioner”) denying Plaintiff’s application for disability and disability insurance 14 benefits pursuant to Title II of the Social Security Act. Currently before the Court is Plaintiff’s 15 motion to reverse and remand. Docket No. 9. The Commissioner filed a responsive brief. Docket 16 No. 12. Plaintiff filed a reply. Docket No. 13. The parties consent to resolution of this matter by 17 the undersigned magistrate judge. Docket No. 3; see also Gen. Order. 2023-12. 18 I. STANDARDS 19 A. Judicial Standard of Review 20 The Court’s review of administrative decisions in social security disability benefits cases 21 is governed by 42 U.S.C. § 405(g). Akopyan v. Barnhart, 296 F.3d 852, 854 (9th Cir. 2002). 22 Section 405(g) provides that, “[a]ny individual, after any final decision of the Commissioner of 23 Social Security made after a hearing to which he was a party, irrespective of the amount in 24 controversy, may obtain a review of such decision by a civil action...brought in the district court 25 of the United States for the judicial district in which the plaintiff resides.” The Court may enter, 26 “upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing 27 the decision of the Commissioner of Social Security, with or without remanding the cause for a 28 rehearing.” Id. 1 The Commissioner’s findings of fact are deemed conclusive if supported by substantial 2 evidence. Id. To that end, the Court must uphold the Commissioner’s decision denying benefits 3 if the Commissioner applied the proper legal standard and there is substantial evidence in the 4 record as a whole to support the decision. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). 5 Substantial evidence is “more than a mere scintilla,” which equates to “such relevant evidence as 6 a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 7 U.S. 97, 139 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Id. In 8 determining whether the Commissioner’s findings are supported by substantial evidence, the Court 9 reviews the administrative record as a whole, weighing both the evidence that supports and the 10 evidence that detracts from the Commissioner’s conclusion. Reddick v. Chater, 157 F.3d 715, 720 11 (9th Cir. 1998). 12 Under the substantial evidence test, the Commissioner’s findings must be upheld if 13 supported by inferences reasonably drawn from the record. Batson v. Comm’r, Soc. Sec. Admin., 14 359 F.3d 1190, 1193 (9th Cir. 2004). When the evidence will support more than one rational 15 interpretation, the Court must defer to the Commissioner’s interpretation. Burch v. Barnhart, 400 16 F.3d 676, 679 (9th Cir. 2005). Consequently, the issue before this Court is not whether the 17 Commissioner could reasonably have reached a different conclusion, but whether the final decision 18 is supported by substantial evidence. 19 It is incumbent on the Administrative Law Judge (“ALJ”) to make specific findings so that 20 the Court does not speculate as to the basis of the findings when determining if the Commissioner’s 21 decision is supported by substantial evidence. The ALJ’s findings should be as comprehensive 22 and analytical as feasible and, where appropriate, should include a statement of subordinate factual 23 foundations on which the ultimate factual conclusions are based, so that a reviewing court may 24 know the basis for the decision. See, e.g., Gonzalez v. Sullivan, 914 F.2d 1197, 1200 (9th Cir. 25 1990). 26 B. Benefits Evaluation Process 27 The individual seeking disability benefits bears the initial burden of proving disability. 28 Roberts v. Shalala, 66 F.3d 179, 182 (9th Cir. 1995). To meet this burden, the individual must 1 demonstrate the “inability to engage in any substantial gainful activity by reason of any medically 2 determinable physical or mental impairment which can be expected...to last for a continuous period 3 of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). More specifically, the individual must 4 provide “specific medical evidence” in support of his claim for disability. See, e.g., 20 C.F.R. § 5 404.1514. If the individual establishes an inability to perform his prior work, then the burden 6 shifts to the Commissioner to show that the individual can perform other substantial gainful work 7 that exists in the national economy. Reddick, 157 F.3d at 721. 8 The ALJ follows a five-step sequential evaluation process in determining whether an 9 individual is disabled. Bowen v. Yuckert, 482 U.S. 137, 140 (1987) (citing 20 C.F.R. §§ 404.1520, 10 416.920). If at any step the ALJ determines that he can make a finding of disability or 11 nondisability, a determination will be made and no further evaluation is required. See Barnhart v. 12 Thomas, 540 U.S. 20, 24 (2003); see also 20 C.F.R. § 404.1520(a)(4). The first step requires the 13 ALJ to determine whether the individual is currently engaging in substantial gainful activity 14 (“SGA”). 20 C.F.R. § 404.1520(b). SGA is defined as work activity that is both substantial and 15 gainful; it involves doing significant physical or mental activities usually for pay or profit. 20 16 C.F.R. § 404.1572(a)-(b). If the individual is currently engaging in SGA, then a finding of not 17 disabled is made. If the individual is not engaging in SGA, then the analysis proceeds to the second 18 step. 19 The second step addresses whether the individual has a medically determinable impairment 20 that is severe or a combination of impairments that significantly limits him from performing basic 21 work activities. 20 C.F.R. § 404.1520(c). An impairment or combination of impairments is not 22 severe when medical and other evidence does not establish a significant limitation of an 23 individual's ability to work. See 20 C.F.R. §§ 404.1521, 404.1522. If the individual does not have 24 a severe medically determinable impairment or combination of impairments, then a finding of not 25 disabled is made. If the individual has a severe medically determinable impairment or combination 26 of impairments, then the analysis proceeds to the third step. 27 The third step requires the ALJ to determine whether the individual’s impairments or 28 combination of impairments meet or medically equal the criteria of an impairment listed in 20 1 C.F.R.

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