Tammy Renee Henderson v. Frank Bisignano, Commissioner of Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedNovember 6, 2025
Docket4:25-cv-00576
StatusUnknown

This text of Tammy Renee Henderson v. Frank Bisignano, Commissioner of Social Security Administration (Tammy Renee Henderson v. Frank Bisignano, Commissioner of Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tammy Renee Henderson v. Frank Bisignano, Commissioner of Social Security Administration, (D.S.C. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION Tammy Renee Henderson, ) Civil Action No.: 4:25-cv-00576-RMG-TER ) Plaintiff, ) REPORT AND RECOMMENDATION ) -vs- ) ) Frank Bisignano,1 ) Commissioner of Social Security ) Administration, ) ) Defendant. ) ___________________________________ ) This is an action brought pursuant to Section 205(g) of the Social Security Act, as amended, 42 U.S.C. Section 405(g), to obtain judicial review of a “final decision” of the Commissioner of Social Security, denying Plaintiff’s claim for disability insurance benefits (DIB) and supplemental security income(SSI). The only issues before the Court are whether the findings of fact are supported by substantial evidence and whether proper legal standards have been applied. I. RELEVANT BACKGROUND A. Procedural History Plaintiff filed an application for DIB and SSI in December 2020, alleging inability to work since December 2020 (Tr. 14). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a hearing. A hearing was held in November 2023, at which time Plaintiff and a vocational expert (VE) testified. (Tr. 14). The Administrative Law Judge (ALJ) issued an unfavorable decision on January 11, 2024, finding that Plaintiff was not disabled within the meaning of the Act. (Tr. 14-25). Plaintiff filed a request for review of the ALJ’s decision. The 1Frank Bisignano became the Commissioner of Social Security in May 2025. Pursuant to Fed. R. Civ. P. 25(d), he is automatically substituted. Appeals Council denied the request for review in December 2024, making the ALJ’s decision the Commissioner’s final decision. (Tr.1-3). Plaintiff filed this action in January 2025. (ECF No. 1). B. Background 1. Introductory Facts

Plaintiff was born in March 1977 and was forty-three years old at the time of the alleged onset. (Tr. 23). Plaintiff has past work experience as a janitor and industrial cleaner. (Tr. 23). Plaintiff alleges disability originally due to congestive heart failure and asthma. (Tr. 60). Pertinent records will be addressed under the relevant issue headings. 2. The ALJ’s Decision In the decision of January 11, 2024, the ALJ made the following findings of fact and conclusions of law (Tr. 14-25):

1. The claimant meets the insured status requirements of the Social Security Act through June 30, 2024 (Exhibit 12D). 2. The claimant has not engaged in substantial gainful activity since December 17, 2020, the alleged onset date (20 CFR 404.1571 et seq., and 416.971 et seq.). 3. The claimant has the following severe impairments: degenerative disc disease, degenerative joint disease of the right knee, congestive heart failure, hypertension, asthma, anemia, and obesity (20 CFR 404.1520(c) and 416.920(c)). 4. The claimant does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 404.1525, 404.1526, 416.920(d), 416.925 and 416.926). 5. After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a) except that she can never climb; can occasionally balance, stoop, kneel, crouch, and crawl; can 2 frequently tolerate exposure to extreme cold/heat, humidity, and pulmonary irritants; and should have no exposure to workplace hazards. 6. The claimant is unable to perform any past relevant work (20 CFR 404.1565 and 416.965). 7. The claimant was born on March 23, 1977, and was 43 years old, which is defined as a younger individual age 18-44, on the alleged disability onset date. The claimant subsequently changed age category to a younger individual age 45-49 (20 CFR 404.1563 and 416.963). 8. The claimant has a limited education (20 CFR 404.1564 and 416.964). 9. Transferability of job skills is not material to the determination of disability because using the Medical-Vocational Rules as a framework supports a finding that the claimant is “not disabled,” whether or not the claimant has transferable job skills (See SSR 82-41 and 20 CFR Part 404, Subpart P, Appendix 2). 10. Considering the claimant’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that the claimant can perform (20 CFR 404.1569, 404.1569a, 416.969, and 416.969a). 11. The claimant has not been under a disability, as defined in the Social Security Act, from December 17, 2020, through the date of this decision (20 CFR 404.1520(g) and 416.920(g)). II. DISCUSSION Plaintiff argues the ALJ’s analysis of Dr. Ezman’s opinions does not comply with the required regulatory analysis. (ECF No. 14 at 27-29). Plaintiff argues the ALJ failed to properly evaluate joint pain, shortness of breath, and fatigue in performing the subjective symptom evaluation. (ECF No. 14 at 18). Plaintiff argues the ALJ wrongfully discounted Plaintiff’s testimony regarding the frequency of vomiting and headaches, citing only an OCR search of the record; Defendant notes some episodes of vomiting predated the alleged onset date or were viral caused and that many of the headache cites are before the relevant period, in past history, or duplicates. (ECF No. 14 at 29); (ECF 3 No. 16 at 17-20). Plaintiff argues: “The ALJ completely disregarded Plaintiff’s depression and anxiety, and generally diminished her memory and concentration issues.” (ECF No. 14 at 30). Despite Plaintiff regularly getting treatment as displayed in the 1,479 page record, Plaintiff argues the ALJ failed to address lack of insurance and lack of medical evidence under Lovejoy because

page 1439 in the record stated “going to refer her to pulmonologist once she got insurance.” (ECF No. 14 at 30-33). Defendant argues the ALJ’s analysis here was sufficient, was in accordance with the applicable law, and Plaintiff has failed to show that the ALJ’s decision is not based on substantial evidence. A. LEGAL FRAMEWORK 1. The Commissioner’s Determination–of–Disability Process

The Act provides that disability benefits shall be available to those persons insured for benefits, who are not of retirement age, who properly apply, and who are under a “disability.” 42 U.S.C. § 423(a).

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Bluebook (online)
Tammy Renee Henderson v. Frank Bisignano, Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tammy-renee-henderson-v-frank-bisignano-commissioner-of-social-security-scd-2025.