Williams v. Bisignano

CourtDistrict Court, W.D. Texas
DecidedAugust 27, 2025
Docket3:25-cv-00055
StatusUnknown

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

Bluebook
Williams v. Bisignano, (W.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS EL PASO DIVISION

ANDRE WILLIAMS, § § Plaintiff, § v. § EP-25-CV-00055-ATB § FRANK BISIGNANO, Commissioner of the § Social Security Administration, § § Defendant. §

MEMORANDUM OPINION AND ORDER

This is a civil action seeking judicial review of an administrative decision by the Social Security Administration (SSA). Pursuant to 42 U.S.C. § 405(g), Plaintiff Andre Williams, the claimant at the administrative level, appeals from the final decision of Defendant Frank Bisignano, the SSA’s Commissioner, denying his claim for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. § 401, et seq. The parties consented to have a magistrate judge conduct all proceedings, including the entry of final judgment. For the reasons that follow, the Commissioner’s decision is AFFIRMED. I. BACKGROUND

On June 1, 2023, Williams applied for disability insurance benefits, alleging that he became disabled as of March 1, 2023, due to lumbar spinal stenosis, hip osteoarthritis, and pain in his lower back, hip, and sacroiliac joint;1 after filing the application, Williams alleged major depressive disorder as a further basis of his disability.2 He was 57 years old when he applied for

1 Tr. of Admin. R. [hereinafter Tr.] at 175, 214.

2 Id. at 40, 322. benefits.3 He has a master’s degree in public health education.4 Between 1990 and 2010, Williams served in the U.S. Army as a combat engineer, and between September 2013 and February 2023, he worked as a program specialist and coordinator for the Army’s community service program at Fort Bliss, Texas.5 In 2021, the Department of Veterans Affairs assigned him a 100-percent combined disability rating, effective July 14, 2021.6 In February 2023, he stopped

working because, according to him, his medical conditions got a lot worse.7 Williams’s benefits claim was denied initially on January 4, 2024, and upon reconsideration on March 14, 2024. Thereafter, Williams requested a hearing before an Administrative Law Judge (ALJ). On October 3, 2024, ALJ Richard Exnicios held a hearing, where Williams and a vocational expert (VE) testified; at the hearing, Williams was represented by his administrative counsel. On October 22, 2024, ALJ Exnicios issued a written decision, wherein he found that Williams was not disabled within the meaning of the Social Security Act and denied Williams’s claim.8 On November 19, 2024, Williams appealed to the Social Security Appeals Council for review of the ALJ’s decision.9 On January 3, 2025, the Appeals Council

3 Id. at 175.

4 Id. at 34, 215.

5 Id. at 35–36, 215, 231.

6 Id. at 36–37, 1318.

7 Id. at 34–35.

8 Id. at 23.

9 Id. at 169–70. denied his request for review, finding that no basis existed for changing the ALJ’s decision.10 The ALJ’s decision thereby became the “final decision” of the Commissioner.11 On February 24, 2025, Williams brought this action seeking judicial review of the Commissioner’s decision pursuant to 42 U.S.C. § 405(g). On May 28, 2025, Williams filed his opening brief requesting that the Commissioner’s decision be vacated and his claim be remanded

for further proceedings. Pl.’s Br. at 11, ECF No. 10. On July 25, 2025, the Commissioner filed a brief in response requesting that the Court affirm the Commissioner’s decision, Br. in Supp. of Comm’r’s Decision at 7 [hereinafter Def.’s Resp.], ECF No. 14, and Williams followed by filing a reply on August 8, 2025, Pl.’s Reply Br. [hereinafter Pl.’s Reply], ECF No. 15. II. STANDARDS FOR JUDICIAL REVIEW

Judicial review, under 42 U.S.C. § 405(g), of the Commissioner’s decision denying social security benefits is “highly deferential.” Garcia v. Berryhill, 880 F.3d 700, 704 (5th Cir. 2018). Courts review such a decision “only to ascertain whether (1) the final decision is supported by substantial evidence and (2) whether the Commissioner used the proper legal standards to evaluate the evidence.” Webster v. Kijakazi, 19 F.4th 715, 718 (5th Cir. 2021) (quotation marks and citation omitted). Substantial evidence “means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (internal quotes omitted). It consists of “more than a mere scintilla,” id, but “less than a preponderance of the evidence,” Schofield v. Saul, 950 F.3d 315, 320 (5th Cir. 2020). “And

10 Id. at 1.

11 See 42 U.S.C. § 405(g) (providing that a claimant may obtain judicial review of any “final decision” of the Commissioner of Social Security); Higginbotham v. Barnhart, 405 F.3d 332, 336 (5th Cir. 2005) (“[W]hen the Appeals Council denies a request for review, the ALJ’s decision becomes the Commissioner’s final decision.”). whatever the meaning of ‘substantial’ in other contexts, the threshold for such evidentiary sufficiency is not high.” Biestek, 587 U.S. at 103. “A finding of no substantial evidence is appropriate only if no credible evidentiary choices or medical findings support the decision.” Whitehead v. Colvin, 820 F.3d 776, 779 (5th Cir. 2016). In applying the substantial evidence standard, a reviewing court “scrutinizes the record to

determine whether such evidence is present,” Sun v. Colvin, 793 F.3d 502, 508 (5th Cir. 2015), but it may not “reweigh the evidence in the record” or “try the issues de novo,” Salmond v. Berryhill, 892 F.3d 812, 817 (5th Cir. 2018). “[N]or, in the event of evidentiary conflict or uncertainty,” may the court “substitute [its] judgment for the Commissioner’s, even if [it] believe[s] the evidence weighs against the Commissioner’s decision.” Garcia, 880 F.3d at 704 (internal quotes omitted). “Conflicts of evidence are for the Commissioner, not the court[], to resolve.” Perez v. Barnhart, 415 F.3d 457, 461 (5th Cir. 2005) III. THE SEQUENTIAL EVALUATION PROCESS AND THE ALJ’S KEY FINDINGS AND CONCLUSIONS

Eligibility for disability insurance benefits requires that the claimant be “disabled” within the meaning of the Social Security Act. 42 U.S.C. § 423(a)(1)(E). The Act defines “disability” as an “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment . . . which has lasted or can be expected to last for a continuous period of not less than 12 months.” Id. § 423(d)(1)(A). “A claimant has the burden of proving he suffers from a disability.” Garcia, 880 F.3d at 704. To determine disability, the Commissioner uses a sequential, five-step approach, which considers: (1) whether the claimant is presently performing substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals a listed impairment; (4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from performing any other substantial gainful activity.

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Bluebook (online)
Williams v. Bisignano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-bisignano-txwd-2025.