William F. Limber v. Frank Bisignano, Commissioner, Social Security Administration

District Court, E.D. Arkansas·Decided June 2, 2026·No. 4:25-cv-00916·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

WILLIAM F. LIMBER PLAINTIFF

V. No. 4:25-CV-00916-KGB-PSH

FRANK BISIGNANO, Commissioner, Social Security Administration DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to Chief United States District Judge Kristine G. Baker. You may file written objections to all or part of this Recommendation. If you do so, those objections must: (1) specifically explain the factual and/or legal basis for your objection; and (2) be received by the Clerk of this Court within 14 days of the date of this Recommendation. If you do not file objections, Chief Judge Baker may adopt this Recommendation without independently reviewing all of the evidence in the record. By not objecting, you may waive the right to appeal questions of fact. I. INTRODUCTION On June 21, 2022, William F. Limber (“Mr. Limber”) filed an application for Title II disability benefits, and on December 16, 2022, he filed a Title XVI application for supplemental security income. (Tr. at 17). He alleged that his disability began on April 4, 2021.1 Id. The claims were denied at the initial and reconsideration levels. Id. Following a hearing, an Administrative Law Judge

(“ALJ”) found that Mr. Limber was not disabled. (Tr. at 17-29). The Appeals Council denied Mr. Limber’s request for review of the ALJ’s decision. (Tr. at 1-6). The ALJ’s decision now stands as the final decision of the Commissioner. For

the reasons stated below, the Court recommends that the Commissioner’s decision be affirmed. II. THE COMMISSIONER’S DECISION

The ALJ found, at Step One, that Mr. Limber (who was 55 years old on the alleged onset date) has not engaged in substantial gainful activity since May 25, 2022, the amended alleged onset date.2 (Tr. at 19, 26). At Step Two, the ALJ determined that Mr. Limber has the following severe impairments: obesity,

degenerative disc disease of the lumbar spine, compression fracture of the thoracic spine, diabetes mellitus with hyperglycemia, osteopenia, osteoarthritis of the right shoulder, seizure disorder, anxiety, attention deficit hyperactivity disorder, bipolar

1 He subsequently amended his alleged onset date to May 25, 2022. Id.

2 The ALJ followed the required five-step sequence to determine: (1) whether the claimant was engaged in substantial gainful activity; (2) if not, whether the claimant had a severe impairment; (3) if so, whether the impairment (or combination of impairments) met or equaled a listed impairment; (4) if not, whether the impairment (or combination of impairments) prevented the claimant from performing past relevant work; and (5) if so, whether the impairment (or combination of impairments) prevented the claimant from performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 404.1520(a)–(g), 416.920(a)–(g). disorder, major depression, post-traumatic stress disorder, and mood disorder. (Tr. at 20).

At Step Three, the ALJ determined that Mr. Limber’s impairments did not meet or equal a Listing.3 (Tr. at 21-22). Next, the ALJ concluded that Mr. Limber has the residual functional capacity (“RFC”) to perform work at the medium

exertional level with the following additional limitations: (1) no more than occasional climbing of ropes, ladders, or scaffolding; (2) no more than frequent climbing of ramps or stairs; (3) no more than occasional overhead reaching on the right side; (4) no work at unprotected heights and no work around dangerous moving

machinery; (5) no driving; (6) able to understand, remember, and carry out detailed but not complex instructions, but no work performed in a production rate environment (such as assembly line work); (7) limited to occasional interaction with

supervisors, coworkers, and the general public. (Tr. at 23). The ALJ determined at Step Four that Mr. Limber is unable to perform his past relevant work as a bus driver and home health attendant. (Tr. at 26). Based upon Vocational Expert (“VE”) testimony, the ALJ found, based on Mr. Limber’s age,

education, work experience, and RFC, that there are jobs in the national economy that Mr. Limber can perform. (Tr. at 27-28). Therefore, the ALJ concluded that Mr.

3 The Listings define impairments that would prevent an adult, regardless of his age, education, or work experience, from performing any gainful activity, not just “substantial gainful activity.” Sullivan v. Zebley, 493 U.S. 521, 532 (1990). Limber was not disabled. Id. III. DISCUSSION

A. Standard of Review

“In reviewing the ALJ’s decision,” the Court “examine[s] whether it is supported by substantial evidence on the record as a whole and whether the ALJ made any legal errors.” Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015); see also 42 U.S.C. § 405(g). “Substantial evidence is that which a ‘reasonable mind might accept as adequate to support a conclusion,’ whereas substantial evidence on the record as a whole entails ‘a more scrutinizing analysis.’” Reed v. Barnhart, 399 F.3d

917, 920 (8th Cir. 2005) (citations omitted). “Our review ‘is more than an examination of the record for the existence of substantial evidence in support of the Commissioner’s decision . . . . [W]e also take into account whatever in the record

fairly detracts from that decision.’” Gann v. Berryhill, 864 F.3d 947, 950-51 (8th Cir. 2017) (citation omitted). “Reversal is not warranted, however, ‘merely because substantial evidence would have supported an opposite decision.’” Reed, 399 F.3d at 920 (citation omitted).

In clarifying the “substantial evidence” standard applicable to review of administrative decisions, the Supreme Court has explained: “And whatever the meaning of ‘substantial’ in other contexts, the threshold for such evidentiary

sufficiency is not high. Substantial evidence . . . is ‘more than a mere scintilla.’” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). “It means—and means only—‘such relevant

evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. (citation omitted). B. Summary of Medical History

Mr. Limber’s arguments focus on his physical impairments. The Court will limit its discussion thereto.4 Mr. Limber had problems with his back, neck, and right shoulder. Objective imaging confirmed this. A 2022 lumbar x-ray showed mild degenerative changes

and facet arthropathy (Tr. at 952), and a 2023 thoracic spine MRI revealed a compression fracture and bilateral foraminal narrowing, but no spinal canal stenosis (Tr. at 1020-1021). A right shoulder x-ray in 2022 showed chronic degenerative

changes, but no acute fracture. (Tr. at 954). Musculoskeletal examinations showed some tenderness, but mostly normal range of motion, negative straight-leg raises, and normal gait and posture.5 (Tr. at 351-358. 369, 495-496, 600-621, 905-920, 1108-1116, 1184-1185, 1357-1383). Mr. Limber admitted to doing heavy lifting in

April 2022, when he heard a pop in his left shoulder. (Tr. at 611-614). But, at that

4 See Noerper v.

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William F. Limber v. Frank Bisignano, Commissioner, Social Security Administration, (E.D. Ark. 2026).

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