Thomas v. Bisignano (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedSeptember 16, 2025
Docket2:24-cv-00229
StatusUnknown

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

Bluebook
Thomas v. Bisignano (CONSENT), (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

DONNIE T. ) ) Plaintiff, ) ) v. ) CASE NO. 2:24-cv-229-JTA ) (WO) FRANK BISIGNANO,1 Commissioner ) of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff Donnie T. brings this action to review a final decision by the Commissioner of Social Security (“Commissioner”). (Doc. No. 1.)2 The Commissioner denied Plaintiff’s application for Supplemental Security Income (“SSI”) and claim for a period of disability and Disability Insurance Benefits (“DIB”). The Court construes Plaintiff’s memorandum in support of his Complaint (Doc. No. 13) as a motion for summary judgment and the Commissioner’s memorandum in support of the Commissioner’s decision as a motion for summary judgment (Doc. No. 17). The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). (Docs. No. 6, 7.)

1 Frank Bisignano became the Commissioner of Social Security on May 6, 2025, and under Federal Rule of Civil Procedure 25(d) is automatically substituted as the defendant. See Fed. R. Civ. P. 25(d).

2 Document numbers as they appear on the docket sheet are designated as “Doc. No.” After scrutiny of the record and the motions submitted by the parties, the Court finds that Plaintiff’s motion for summary judgment is due to be DENIED, the Commissioner’s

motion for summary judgment is due to be GRANTED, and the decision of the Commissioner is due to be AFFIRMED. I. PROCEDURAL HISTORY AND FACTS Plaintiff is an adult male3 with a middle school education and prior work experience as a tow truck driver, forklift operator, garage collector driver, diesel mechanic, and iron worker. (R. 25–26, 299.) 4 He alleged a disability onset date of August 1, 2017, due to plates

and screws in his bilateral wrists, post-traumatic stress disorder (“PTSD”), a neck injury, and carpal tunnel syndrome. (R. 298.) On August 27, 2020, Plaintiff protectively filed a Title II application (42 U.S.C. §§ 401, et seq.) for a period of disability and DIB, and a Title XVI application (42 U.S.C. §§ 1381, et seq.) for SSI. (R. 276–77, 280–85.) The applications were denied initially and

upon reconsideration. (R. 10, 158–63, 165–69, 174–76, 177-78.) Following an administrative hearing, the Administrative Law Judge (“ALJ”) denied Plaintiff’s request for benefits in a decision dated November 3, 2021. (R. 28.) The Appeals Council denied review. (R. 1.) On July 6, 2022, Plaintiff filed suit in the United States District Court for the Middle

District of Alabama. See Donnie T. v. Kijakazi, No. 2:22-cv-395-JTA (M.D. Ala. Nov. 28,

3 Plaintiff was 46 years old on the alleged disability onset date. (R. 26.)

4 Citations to the administrative record are consistent with the transcript of administrative proceedings filed in this case. (See Doc. No. 10.) 2022). On November 28, 2022, the Court remanded the case for further administrative proceedings. See id. The Appeals Council remanded the case to the ALJ, who held a hearing

on July 6, 2023. (R. 561–91, 592–97.) Following the hearing, the ALJ determined Plaintiff had not been disabled and denied his request for benefits on December 19, 2023. (R. 556.) Plaintiff did not appeal the ALJ’s decision, nor did the Appeals Council initiate its own review. Thus, on February 19, 2024, the ALJ’s decision became the final decision of the Commissioner. See 20 C.F.R. §§ 404.984(c)–(d), 416.1484(c)–(d) (“Any time within 60 days after the date of the hearing decision, the Appeals Council may decide to assume

jurisdiction of your case even though no written exceptions have been filed. . . . If no exceptions are filed and the Appeals Council does not assume jurisdiction of your case, the decision of the administrative law judge becomes the final decision of the Commissioner after remand.”). On April 17, 2024, Plaintiff filed this action seeking review of the Commissioner’s

final decision. (Doc. No. 1.) The parties have briefed their respective positions. (Docs. No. 13, 17, 18.) This matter is ripe for review. II. STANDARD OF REVIEW Judicial review of disability claims is limited to whether the Commissioner’s

decision is supported by substantial evidence and whether the correct legal standards were applied. 42 U.S.C. § 405(g); Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005). The court “must scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence.” Schink v. Comm’r of Soc. Sec., 935 F.3d 1245, 1257 (11th Cir. 2019) (citations omitted). “Substantial evidence” is more than a mere scintilla and is “such relevant evidence as a reasonable person would accept as

adequate to support a conclusion.” Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155, 1158 (11th Cir. 2004) (quoting Lewis v. Callahan, 125 F.3d 1346, 1349 (11th Cir. 1997)). Even if the Commissioner’s decision is not supported by a preponderance of the evidence, the findings must be affirmed if they are supported by substantial evidence. Id. at 1158–59; see also Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). The court may not find new facts, reweigh evidence, or substitute its own judgment for that of the Commissioner.

Bailey v. Soc. Sec. Admin., Comm’r, 791 F. App’x 136, 139 (11th Cir. 2019); Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004); Dyer, 395 F.3d at 1210. However, the Commissioner’s conclusions of law are not entitled to the same deference as findings of fact and are reviewed de novo. Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253, 1260 (11th Cir. 2007).

Sentence four of 42 U.S.C. § 405(g) authorizes the district court to “enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the Commissioner of Social Security, with or without remanding the cause for a rehearing.” 42 U.S.C. § 405(g). The district court may remand a case to the Commissioner for a rehearing if the court finds “either . . . the decision is not supported by substantial

evidence, or . . . the Commissioner or the ALJ incorrectly applied the law relevant to the disability claim.” Jackson v. Chater, 99 F.3d 1086, 1092 (11th Cir. 1996). III.

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