Walsh v. Bisignano

CourtDistrict Court, E.D. Missouri
DecidedSeptember 29, 2025
Docket4:24-cv-00841
StatusUnknown

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

Bluebook
Walsh v. Bisignano, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

PHILIP WALSH, ) ) Plaintiff, ) ) ) v. ) Case No. 4:24-CV-00841-SPM ) FRANK BISIGNANO, ) Commissioner of Social Security,1 ) ) ) Defendant. )

MEMORANDUM OPINION

This is an action under 42 U.S.C. § 1383(c)(3) for judicial review of the final decision of Defendant Frank Bisignano, Commissioner of Social Security (the “Commissioner”) denying the application of Plaintiff Philip Walsh (“Plaintiff”) for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381, et seq. (the “Act”). The parties consented to the jurisdiction of the undersigned magistrate judge pursuant to 28 U.S.C. § 636(c). (Doc. 8). Because the Court finds the decision denying benefits was supported by substantial evidence, the Court will affirm the Commissioner’s denial of Plaintiff’s application.

1 Frank Bisignano is now the Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank Bisignano is substituted as the defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). . I. FACTUAL BACKGROUND At the most recent hearing before the ALJ, Plaintiff and his representative communicated that, during the relevant period, Plaintiff suffered from mental health symptoms such as mania, depression, irritability, sleeplessness, paranoia, and hallucinations. (Tr. 1136-37, 1143-44). As a

result, Plaintiff testified that he had difficulty concentrating and interacting with others, lived in constant fear, and walked around “like a zombie.” (Tr. 1137). According to Plaintiff, he sought treatment at Comtrea and was prescribed medications, but nonetheless he struggled to function and to maintain willpower for activities. (Tr. 1137-38). Plaintiff performed household chores such as laundry, cooking, cleaning, and caring for his school-age son, with occasional assistance from his sister and mother. (Tr. 1139-43). Plaintiff testified that once or twice a month, when he was experiencing hallucinations, his son would spend a few days with Plaintiff’s mother or sister. (Tr. 1143). Plaintiff also regularly attended Alcoholics Anonymous (“AA”) meetings and church. (Tr. 1139). The record contains documentation of Plaintiff’s treatment for mental health conditions,

primarily bipolar disorder and anxiety, since at least 2018. Plaintiff has been treated with counseling and various medications. For the relevant period, the record contains opinion evidence from Keith Allen, PhD, an agency consultant, who opined that Plaintiff has some limitations in activities of daily living and social functioning, and that Plaintiff had the mental capacity to carry out “two-step commands” and would work best in a setting where there is “little need for direct supervision or frequent interaction with the public.” (Tr. 505-06). The Court accepts the facts as set forth in the parties’ respective statements of fact and responses. The Court will cite to specific portions of the transcript as needed to address the parties’ arguments. II. PROCEDURAL BACKGROUND On August 28, 2018, Plaintiff applied for SSI, alleging that he had been unable to work since January 11, 2011 due to bipolar disorder type I disorder, schizoaffective disorder, and anxiety. (Tr. 584, 595). On November 14, 2019, Plaintiff amended his alleged onset date to August

28, 2025, his application date. (Tr. 615). His application was denied initially and on reconsideration, and he filed a Request for Hearing by Administrative Law Judge (ALJ). (Tr. 516- 541). After the ALJ denied his claim, he appealed to this court, which remanded his case. (Tr. 1156-1189, 1214). On remand, Plaintiff filed another application and was found disabled with an established onset date of February 23, 2021. (Tr. 1200, 1208). On November 16, 2023, a hearing took place for consideration of whether Plaintiff was disabled during the period from his initial application date, August 28, 2018, through February 22, 2021—in other words, the gap between his initial application and his subsequent application (Tr. 524-26). After a hearing, the ALJ issued an unfavorable decision on February 23, 2024. (Tr. 1108- 1122). The decision of the ALJ stands as the final decision of the Commissioner of the Social

Security Administration. III. STANDARD FOR DETERMINING DISABILITY UNDER THE ACT To be eligible for benefits under the Social Security Act, a claimant must prove he or she is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Sec’y of Health & Hum. Servs., 955 F.2d 552, 555 (8th Cir. 1992). Under the Social Security Act, a person is disabled if he or she is unable “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 12 months.” 42 U.S.C. § 1382c(a)(3)(A). Accord Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010). The impairment must be “of such severity that he [or she] is not only unable to do his [or her] previous work but cannot, considering his [or her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy, regardless of whether such work exists in the immediate area in which he [or she] lives, or whether a specific job vacancy

exists for him [or her], or whether he [or she] would be hired if he [or she] applied for work.” 42 U.S.C. § 1382c(a)(3)(B). To determine whether a claimant is disabled, the Commissioner engages in a five-step evaluation process. 20 C.F.R. § 416.920(a); see also McCoy v. Astrue, 648 F.3d 605, 611 (8th Cir. 2011) (discussing the five-step process). At Step One, the Commissioner determines whether the claimant is currently engaging in “substantial gainful activity”; if so, then the claimant is not disabled. 20 C.F.R. § 416.920(a)(4)(i); McCoy, 648 F.3d at 611. At Step Two, the Commissioner determines whether the claimant has “a severe medically determinable physical or mental impairment that meets the [twelve-month duration requirement in § 416.909], or a combination of impairments that is severe and meets the duration requirement”; if the claimant does not have a

severe impairment, the claimant is not disabled. 20 C.F.R. § 416.920(a)(ii); McCoy, 648 F.3d at 611.

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Walsh v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walsh-v-bisignano-moed-2025.