Thomas J. Snieg v. Frank J. Bisignano, Commissioner of Social Security

CourtDistrict Court, E.D. Wisconsin
DecidedDecember 18, 2025
Docket2:25-cv-00395
StatusUnknown

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

Bluebook
Thomas J. Snieg v. Frank J. Bisignano, Commissioner of Social Security, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

THOMAS J. SNIEG,

Plaintiff, v. Case No. 25-CV-395-JPS

FRANK J. BISIGNANO, Commissioner of Social Security, ORDER

Defendant.

1. INTRODUCTION Under 42 U.S.C. § 405(g), Plaintiff Thomas J. Snieg (“Plaintiff”) seeks judicial review of the final agency decision of the Commissioner of the Social Security Administration (“Defendant”), which denied Plaintiff's application for Disability Insurance Benefits. Upon review of the entire record, and with the benefit of the parties’ arguments, the Court will affirm Defendant’s decision. 2. BACKGROUND 2.1 Legal Framework for Evaluation of Social Security Disability Claims by the Social Security Administration To be eligible for disability benefits under the Social Security Act, a claimant must be deemed “disabled” by the Social Security Administration (“SSA”). 42 U.S.C. § 423(a). In most cases, to determine whether a claimant is disabled within the meaning of the Act, an administrative law judge (“ALJ”) gathers evidence, holds a hearing, takes testimony, and performs a five-step legal evaluation of the claim. 20 C.F.R. § 404.1520. The ALJ must determine whether: (1) the claimant is engaged in “substantial gainful activity”; (2) the claimant has a “severe medically determinable physical or mental impairment”; (3) the claimant’s impairment is equivalent to one of the impairments listed in the appendix of the relevant disability regulation; (4) the impairment prevents the claimant from performing his past relevant work in light of his residual functional capacity (“RFC”); and (5) the claimant, considering his age, education, work experience, and RFC, can still perform another job that is available in the national economy. Id. at § 404.1520(a)(4)(i)–(v). A claimant’s RFC is an assessment of the most a claimant is able to do, notwithstanding his physical and mental limitations. See Elder v. Astrue, 529 F.3d 408, 412 (7th Cir. 2008) (citing 20 C.F.R. § 404.1520(e) and Butera v. Apfel, 173 F.3d 1049, 1054 (7th Cir. 1999)). According to Social Security Ruling (“SSR”) 96-8p, RFC is “an administrative assessment of the extent to which an individual’s medically determinable impairment(s), including any related symptoms, such as pain, may cause physical or mental limitations or restrictions that may affect his or her capacity to do work- related physical and mental activities” in a work setting for eight hours per day, five days a week, or an equivalent work schedule. Titles II & XVI: Assessing Residual Functional Capacity in Initial Claims, SSR 96-8p, 1996 WL 374184, at *2 (S.S.A. July 2, 1996).1 It entails “a function-by-function assessment based upon all of the relevant evidence of an individual’s ability to do work-related activities.” Id. at *3.

1The SSA publishes SSRs that “are binding on all components of the SSA. These rulings represent precedent[ial] final opinions and orders and statements of policy and interpretations that [the SSA has] adopted.” 20 C.F.R. § 402.160(b)(1). The claimant bears the burden of proof in the first four steps of the evaluation. See Young v. Barnhart, 362 F.3d 995, 1000 (7th Cir. 2004). At step five, the burden shifts to the Commissioner to identify specific jobs available in the national economy that the claimant can perform given his impairments and RFC. Id. (citing Zurawski v. Halter, 245 F.3d 881, 886 (7th Cir. 2001)). One additional aspect of the ALJ’s decision-making process merits explanation, as it is relevant to this case. To determine the persuasiveness of a medical opinion, the ALJ considers the following factors: supportability, consistency, the medical professional's relationship with the claimant (including the length of the treatment relationship, frequency of examinations, and purpose and extent of the treatment relationship), specialization, and other facts that tend to support or contradict a medical opinion. Cain v. Bisignano, 148 F.4th 490, 496–97 (7th Cir. 2025) (citing 20 C.F.R. § 416.920c(c)(1)–(5)). Supportability and consistency are the most important of these factors. 20 C.F.R. § 416.920c(a). Indeed, the ALJ is obliged to explain how he or she considered these two factors but need not address the remaining factors. Id. at § 416.920c(b)(1)–(2). In assessing supportability, “ALJs should give more weight to medical opinions with more internal explanation and support than to those without.” Bakke v. Kijakazi, 62 F.4th 1061, 1068 (7th Cir. 2023) (citing 20 C.F.R. § 404.1520c(c)(1)). Supportability, put another way, is an inward-facing inquiry that considers the source’s opinions in comparison to his or her own relevant medical records and explanation. The more internally supported an opinion is, the more persuasive it is. 20 C.F.R. § 416.920c(c)(1). Consistency, by contrast, involves the extent to which the medical opinion is consistent with other medical evidence in the record. Id. at § 416.920c(c)(2). It is a more all-encompassing inquiry focused on how well a medical source is or is not supported by the entire record. The more consistent the opinion is, the more persuasive it is. Id. 2.2 Procedural History2 This case has a fairly lengthy procedural history. It began on October 11, 2018, when Plaintiff filed his application for benefits, alleging disability beginning June 24, 2018. ECF No. 10 at 1. His claim was initially denied on December 6, 2018, then again upon reconsideration on March 26, 2019. Id. ALJ William Shenkenberg held a hearing on July 25, 2019. Id. On August 28, 2019, ALJ Shenkenberg issued an unfavorable decision. Id. On October 22, 2019, the Appeals Council denied Plaintiff’s request for review. Id. Plaintiff then filed for judicial review, and the court remanded the case pursuant to a joint motion. Id. at 2. Following two additional hearings, on January 10, 2022, ALJ Shenkenberg issued another unfavorable decision. Id. On May 16, 2022, the Appeals Council remanded the case. Id. The Court notes that in April 2020, Plaintiff filed another claim for disability insurance benefits, which was ultimately consolidated with his original claim. ECF No. 12 at 3. That claim was therefore part of what was addressed by ALJ Shenkenberg in 2022 and subsequently remanded by the Appeals Council. Id. On September 27, 2022, Plaintiff attended another hearing, this time with ALJ Brent Bedwell. ECF No. 10 at 2. On October 18, 2022, ALJ Bedwell also denied Plaintiff’s claim. Id. Plaintiff again filed a complaint with this

2Citations to the underlying record found in the parties’ briefs have been omitted for brevity and clarity.

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Thomas J. Snieg v. Frank J. Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-j-snieg-v-frank-j-bisignano-commissioner-of-social-security-wied-2025.