Kane v. Bisignano

Case No. 24-cv-2275 (SGE) · United States District Court, District of Minnesota · August 12, 2025 · No. 24-cv-2275 (SGE)

Summary

This United States District Court order reviews the Social Security Administration’s final denial of disability insurance benefits for Plaintiff Patricia K. The Magistrate Judge evaluates whether the Administrative Law Judge’s decision was supported by substantial evidence, specifically addressing the classification of mental impairments at step two and the residual functional capacity determination at step four. Finding no legal error and concluding the ALJ properly weighed conflicting medical opinions, the Court affirms the Commissioner’s decision, denies the Plaintiff’s motion for judicial review, and dismisses the case.

Court
United States District Court, District of Minnesota
Writing for the Court
Shannon G. Elkins
Jurisdiction
United States District Court, District of Minnesota
Decision date
August 12, 2025
Docket number
24-cv-2275 (SGE)
Procedural posture
Plaintiff seeks judicial review of the Commissioner’s final decision under 42 U.S.C. § 405(g); the district court reviews the ALJ’s decision for substantial evidence.
Standard of review
Substantial evidence standard under 42 U.S.C. § 405(g).
Precedential value
nonprecedential
Parties
Patricia K. v. Frank Bisignano, Commissioner of Social Security
Disposition
dismissed

Topics

judicial review of agency actionadministrative lawdisability definitionada / disability

Practice areas

administrative lawdisability law

Questions Presented

  1. Whether the ALJ erred in classifying Plaintiff’s mental impairments as non‑severe under 20 C.F.R. § 404.1520a(d)(1).
  2. Whether the ALJ’s residual functional capacity finding was supported by substantial evidence in the record as a whole.
  3. Whether the Commissioner’s final decision is supported by substantial evidence and should be affirmed.

Holdings

  1. The ALJ did not err; the classification of the mental impairments as non‑severe was supported by substantial evidence.
  2. The ALJ’s RFC finding was supported by substantial evidence and therefore affirmed.
  3. The Court affirms the Commissioner’s final decision and dismisses the case.

Key quotations

“Substantial evidence is less than a preponderance, but enough that a reasonable mind might accept as adequate to support a conclusion.”
“The ALJ must also build a logical bridge between the RFC and the evidence.”

Factual background

Patricia K. applied for disability insurance benefits on March 1, 2017, alleging arthritis, shoulder pain, diabetes, and peripheral neuropathy. She amended her onset date to November 27, 2015, the date of her 50th birthday, and her earnings record limited eligibility to December 31, 2016. The ALJ found her non‑disabled at both the initial and remand hearings, concluding she could perform sedentary work as a medical transcriptionist.

Procedural history

Plaintiff applied for SSDI in 2017; an ALJ denied benefits; the Appeals Council vacated and remanded; a second ALJ again denied benefits; the Commissioner issued a final decision which Plaintiff appealed to this district court.

Court Document

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