Ray-Taylor v. Bisignano
- Jeffrey Bryan
- 0:24-cv-01371
- U.S. District Court · District of Minnesota
- 8
In Ray-Taylor v. Bisignano, Judge Jeffrey M. Bryan dismissed with prejudice a mother's appeal on behalf of her minor child seeking Social Security disability benefits, finding that the administrative law judge properly evaluated and rejected the treating neuropsychologist's opinion that the child had more severe functional limitations.
Parents or guardians who file Social Security disability claims on behalf of minor children with conditions such as autism, ADHD, or anxiety disorders, particularly those whose cases involve conflicting medical opinions about the severity of functional limitations.
What happened
In Ray-Taylor v. Bisignano, Rose R-T sued on behalf of her minor child, J.A.G., appealing the Social Security Administration's denial of supplemental security income (SSI) — monthly payments for people with disabilities who have limited income. J.A.G. had been diagnosed with autism spectrum disorder, generalized anxiety disorder, attention deficit hyperactivity disorder, oppositional defiance disorder, and borderline intellectual functioning, among other conditions. A Social Security administrative law judge (ALJ) — the official who decides these claims — found that J.A.G. did not meet the legal standard for disability because he had a marked limitation in only one of six functional areas (attending and completing tasks) rather than the required two marked limitations or one extreme limitation.
The central dispute was whether the ALJ properly handled the opinion of Dr. Jonathan Miller, J.A.G.'s treating neuropsychologist, who concluded that J.A.G. had an extreme limitation in interacting with others and marked limitations in two additional areas. The ALJ found Dr. Miller's opinion unpersuasive, pointing out that J.A.G. was pleasant and cooperative during Dr. Miller's own testing, that there was no significant support in the evaluation for a marked limitation in moving about, that J.A.G. could participate in team sports and track, leave home independently, and care for his younger brother — and that four other medical consultants reached less severe conclusions than Dr. Miller. The plaintiff argued that the ALJ improperly discounted Dr. Miller and that there was overwhelming objective evidence supporting his opinion.
A magistrate judge — a judicial officer who assists the district court — had already recommended denying the appeal, and Judge Jeffrey M. Bryan agreed. The court explained that it is not allowed to reweigh the evidence or substitute its own judgment for the ALJ's; it can only check whether the ALJ's decision was supported by substantial evidence, meaning enough evidence for a reasonable person to reach the same conclusion. Because the ALJ clearly addressed both the required factors — how well Dr. Miller's opinion was supported by his own examination findings, and how consistent it was with other evidence in the record — Judge Bryan found no legal error, overruled the plaintiff's objections, adopted the magistrate judge's recommendation, and dismissed the case with prejudice, meaning it cannot be refiled.
The detailed version
- Ray-Taylor v. Bisignano, Case No. 24-CV-01371 (JMB/SGE), United States District Court, District of Minnesota
- Jeffrey M. Bryan, United States District Judge
- August 18, 2025
Procedural Posture Plaintiff Rose R-T, acting on behalf of her minor child J.A.G., sought judicial review of the Social Security Commissioner's denial of J.A.G.'s application for Supplemental Security Income (SSI). United States Magistrate Judge Shannon G. Elkins issued a Report and Recommendation (R&R) on July 8, 2025, recommending denial of the appeal. Plaintiff timely objected. The Commissioner did not respond. Judge Bryan adopted the R&R and dismissed the case with prejudice.
Administrative Background J.A.G. was diagnosed with autism spectrum disorder, generalized anxiety disorder, ADHD, oppositional defiance disorder, and borderline intellectual functioning/specific learning disorders, among other conditions. An ALJ applied the three-step sequential evaluation framework for child disability claims under 20 C.F.R. § 416.924(a). The ALJ reached the third step — whether J.A.G.'s impairments functionally equaled a listed disability — and evaluated six functional domains under 20 C.F.R. § 416.926a(b)(1). To qualify as disabled, a child must have either a 'marked' limitation in two domains or an 'extreme' limitation in one domain. The ALJ found J.A.G. had a marked limitation only in attending and completing tasks, with less-than-marked limitations in all other domains except moving about and manipulating objects (no limitation). The claim was therefore denied.
Key Medical Opinion Dispute Dr. Jonathan Miller, Ph.D., L.P., J.A.G.'s treating neuropsychologist, opined in November 2020 that J.A.G. had an extreme limitation in interacting and relating with others, and marked limitations in moving about/manipulating objects and caring for himself — findings that, if accepted, would qualify J.A.G. as disabled. The ALJ found Dr. Miller's opinion unpersuasive, citing: (1) J.A.G. was pleasant and cooperative during Dr. Miller's own testing, contradicting an extreme social limitation; (2) the evaluation lacked significant support for a marked limitation in moving about, noting only a 2018 concussion with no residual deficits; (3) J.A.G.'s ability to leave home independently, hold temporary employment, supervise his younger brother, and prepare simple meals; (4) J.A.G.'s participation in football, basketball, and track; (5) a teacher noting only slight problems interacting with others; (6) Dr. Miller's apparent heavy reliance on subjective reports from J.A.G.'s mother. Four other psychological and pediatric consultants reached less severe conclusions than Dr. Miller, finding marked limitation only in attending and completing tasks.
Legal Standard The court reviews the ALJ's decision under the substantial evidence standard — whether the decision is supported by 'more than a scintilla' but potentially less than a preponderance of the evidence. 42 U.S.C. § 405(g); Cox v. Barnhart, 471 F.3d 902, 906 (8th Cir. 2006). The court may not reweigh evidence or substitute its judgment for that of the ALJ. Nash v. Comm'r, 907 F.3d 1086, 1090 (8th Cir. 2018). When the record supports contrary outcomes, the court will not reverse if the ALJ's decision falls within the 'available zone of choice.' Bradley v. Astrue, 528 F.3d 1113, 1115 (8th Cir. 2008).
For evaluating medical opinions, the ALJ must address 'supportability' (whether the opinion is backed by objective medical evidence) and 'consistency' (whether the opinion aligns with other medical and non-medical sources), which are the most important factors. 20 C.F.R. §§ 404.1520c(c)(1)–(2). The ALJ need not use those exact words but must make clear the analysis was performed. Diane M.W., 2022 WL 4377731, at *5 (D. Minn. 2022). Brevity is not reversible error. Grindley v. Kijakazi, 9 F.4th 622, 631 (8th Cir. 2021).
Plaintiff's Objection and Court's Ruling Plaintiff argued the Magistrate Judge misapplied the standard by failing to treat supportability and consistency as two separate factors, and that the ALJ's discounting of Dr. Miller was grossly inconsistent with the record. Judge Bryan disagreed, finding that the ALJ's written evaluation clearly addressed both factors — explaining internal inconsistencies in Dr. Miller's own examination findings (supportability) and contradictions with other medical sources and record evidence (consistency). The court held that the plaintiff's argument amounted to a request to reweigh evidence, which is impermissible under the applicable standard of review.
Disposition
- Plaintiff's objections to the R&R — OVERRULED
- R&R — ADOPTED
- Case — DISMISSED WITH PREJUDICE
Reviewer note from the AI+
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.