Triplett v. Bisignano

CourtDistrict Court, N.D. Illinois
DecidedAugust 27, 2025
Docket1:23-cv-00056
StatusUnknown

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

Bluebook
Triplett v. Bisignano, (N.D. Ill. 2025).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

NALENA T.,1 ) ) Plaintiff, ) ) Case No. 23 C 0056 v. ) ) Magistrate Judge Laura K. McNally FRANK BISIGNANO, ) Commissioner of ) Social Security,2 ) ) Defendant. )

ORDER3

Before the Court is Plaintiff Nalena T.’s memorandum in support of summary judgment, asking the Court to remand the Administrative Law Judge’s (“ALJ”) decision denying her applications for disability benefits (Dkt. 16: Pl. Mem. in Support of Summ. J.: “Pl. Mem.”) and Defendant’s motion and memorandum in support of summary

1 The Court in this order is referring to Plaintiff by her first name and first initial of her last name in compliance with Internal Operating Procedure No. 22 of this Court.

2 The Court substitutes Frank Bisignano for his predecessor, Leland Dudek, as the proper defendant in this action pursuant to Federal Rule of Civil Procedure 25(d) (a public officer’s successor is automatically substituted as a party).

3 On January 25, 2023, by consent of the parties and pursuant to 28 U.S.C. § 636(c) and Local Rule 73.1, this case was reassigned to the magistrate judge for all proceedings, including entry of final judgment. (Dkt. 10.) judgment (Dkt. 21: Def. Mot. for Summ. J.; Dkt. 22: Def. Mem. in Support of Summ. J.: “Resp.”)

I. Procedural History Plaintiff filed her application for disability insurance benefits and for supplement security income on February 21, 2020. (R. 224-236.) She alleged that her onset date was

December 1, 2019. (Id.) Her date last insured was December 31, 2020. (R. 14.) On October 21, 2021, Plaintiff appeared for a hearing before ALJ Luke Woltering. (R. 40-63.) The ALJ heard testimony from Plaintiff, who was represented by an attorney,

and a vocational expert. On March 29, 2022, the ALJ found Plaintiff not disabled from her onset date through the date of his decision. (R. 13-34.) The Appeals Council denied review (R. 1-6), making the ALJ’s decision the final decision of the Commissioner. Pufahl v. Bisignano, No. 24-1545, 2025 WL 1742967 (7th Cir. June 24, 2025). After considering the

ALJ’s opinion and the parties’ briefs, the Court affirms the ALJ’s decision and denies Plaintiff’s motion for remand. II. ALJ Decision

The ALJ applied the Social Security Administration’s five-step sequential evaluation process to Plaintiff’s claims. At Step One, he found that Plaintiff had not engaged in substantial gainful activity since her onset date. (R. 16.) At Step Two, the ALJ determined that Plaintiff had the severe impairments of degenerative joint disease

of the right knee status post surgery; asthma; decreased hearing in the left ear; decreased vision in the left eye; obesity; and major depressive disorder and bipolar disorder. (Id.) At Step Three, the ALJ found that none of Plaintiff’s impairments met a

Listing. (R. 17.) As part of this determination, the ALJ undertook the “Part B” analysis to assess mental limitations. (R. 18.) He found that Plaintiff had moderate limitations in all four of the criteria: understanding, remembering, and applying information; interacting

with others; concentrating, persisting, and maintaining pace; and adapting and managing herself. (R. 18-20.) Next, the ALJ determined that Plaintiff had the residual functional capacity to

perform light work, with the following additional restrictions: Limited to stand and walk in combination up to two hours in an eight-hour day; can occasionally push and pull with the right lower extremity; cannot climb ladders, ropes, or scaffolds or balance; can occasionally climb ramps and stairs, kneel, couch, and crawl; cannot work around hazards such as unprotected heights and exposed moving mechanical parts’ cannot tolerate more than occasional, concentrated exposure to flames, noxious odors, dusts, mists, gases , and poor ventilation; can understand, remember, and carry out simple work instructions and can sustain concentration to perform simple routine, repetitive tasks; can adapt to simple routine changes and pressures in the work setting; can interact with coworkers and supervisors performing job duties that do not involve tandem tasks or teamwork; and should have no more than incidental contact with the public. (R. 21-22.)_

At Step Four the ALJ found that Plaintiff could perform her past work as a fast- food worker and mail handler, as those jobs are generally performed. (R. 29.) Therefore, the ALJ found that Plaintiff was not disabled. (R. 30.) III. Legal Standard Under the Act, a person is disabled if he has an “inability to engage in any

substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. §

423(d)(1)(a). To determine whether a plaintiff is disabled, the ALJ considers the following five questions, known as “steps,” in order: (1) Is the plaintiff presently unemployed? (2)

Does the plaintiff have a severe impairment? (3) Does the impairment meet or medically equal one of a list of specific impairments enumerated in the regulations? (4) Is the plaintiff unable to perform his former occupation? and (5) Is the plaintiff unable to perform any other work? 20 C.F.R. § 416.920(a)(4).

An affirmative answer at either Step Three or Step Five leads to a finding that the plaintiff is disabled. Young v. Sec'y of Health & Human Servs., 957 F.2d 386, 389 (7th Cir. 1992). A negative answer at any step other than at Step Three precludes a finding of

disability. Id. The plaintiff bears the burden of proof at Steps One to Four. Id. Once the plaintiff shows an inability to perform past work, the burden then shifts to the Commissioner to show the plaintiff's ability to engage in other work that exists in significant numbers in the national economy. Id. The Court does not “merely rubber stamp the ALJ's decision on judicial review.” Prill v. Kijakazi, 23 F.4th 738, 746 (7th Cir. 2022). An ALJ’s decision will be affirmed if it

is supported by “substantial evidence,” which means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Id.

ALJs are “subject to only the most minimal of articulation requirements” and “need not address every piece or category of evidence identified by a claimant, fully summarize the record, or cite support for every proposition or chain of reasoning.” Warnell v.

O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024). “All we require is that ALJs provide an explanation for how the evidence leads to their conclusions that is sufficient to allow us, as a reviewing court, to assess the validity of the agency’s ultimate findings and afford the appellant meaningful judicial review.” Id. at 1054.

The Seventh Circuit added that “[a]t times, we have put this in the shorthand terms of saying an ALJ needs to provide a ‘logical bridge from the evidence to his conclusion.’” Id. (citation omitted). The Seventh Circuit has further clarified that district

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Triplett v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/triplett-v-bisignano-ilnd-2025.