Donacick v. Bisignano

Case: Donacick v. Bisignano, Civil No. 24-2685 (JRT/SGE), United States District Court, District of Minnesota. Decided September 30, 2025, by United States District Judge John R. Tunheim.

Background and Procedural History Plaintiff Karrissa D. filed for Social Security disability insurance benefits on January 16, 2021, alleging disability onset on January 3, 2021. Her claimed impairments included polycystic ovarian syndrome, right knee patellofemoral dysfunction, left shoulder tendinopathy, psychogenic seizures, borderline personality disorder, post-traumatic stress disorder (PTSD), generalized anxiety disorder, depression, iron deficiency anemia, gastroesophageal reflux disease, and obesity. The Social Security Administration denied the application at the initial level, again on reconsideration, and an ALJ denied it after a hearing. The Appeals Council found no basis to disturb the ALJ's decision.

Karrissa D. appealed to federal district court, arguing the ALJ erred in: (1) creating an illogical training period distinction for workplace interaction limits; (2) failing to include a superficial contact limitation in the Residual Functional Capacity (RFC) assessment; and (3) failing to properly limit public interaction in the RFC. Magistrate Judge Shannon G. Elkins issued a Report and Recommendation (R. & R.) recommending denial of Karrissa D.'s request for relief and affirmance of the Commissioner's denial. Karrissa D. timely objected.

Legal Standards The court reviews properly objected-to portions of an R. & R. de novo for dispositive matters, but objections that merely restate arguments already presented to the magistrate judge are reviewed only for clear error. The court found that both of Karrissa D.'s main objections were restatements of arguments already made before the magistrate judge and therefore subject only to clear error review — though the court noted it found no error even under de novo review.

Review of the Commissioner's disability determination is limited to whether the decision is supported by 'substantial evidence' — meaning relevant evidence that a reasonable mind would find adequate to support the conclusion. 42 U.S.C. § 405(g). The ALJ must build a 'logical bridge' tracing the path of reasoning to the RFC determination. The court may not reverse merely because substantial evidence could support a different outcome, and if two reasonable conclusions can be drawn, the Commissioner's must be affirmed.

The Five-Step Sequential Analysis The ALJ applied the required five-step Social Security disability analysis: (1) Karrissa D. did not engage in substantial gainful activity during the relevant period (her Door Dash work did not qualify); (2) she had multiple severe impairments; (3) her impairments did not meet any listed qualifying impairment; (4) she had no past relevant work; (5) jobs existed in significant numbers in the national economy that she could perform, based on vocational expert testimony. The ALJ therefore found she was not disabled.

RFC and the Training Period Distinction Before step four, the ALJ assessed her RFC — the most she could still do despite her limitations. The ALJ found she could perform simple, routine, and repetitive tasks; frequently interact with supervisors and co-workers during an initial training period not exceeding 30 days; and only occasionally interact with supervisors, co-workers, and the public after training. The ALJ found the reconsideration psychologist's opinion 'generally persuasive' but departed from it in two ways: (a) imposing an 'occasional public interaction' limit rather than 'brief and superficial interactions away from the public,' and (b) allowing more frequent interaction during the training period.

The ALJ justified the training period distinction by pointing to: (1) records showing Karrissa D. could engage normally with medical providers; (2) work history showing no problems getting along with others during initial training periods; and (3) her Door Dash employment, where she delivered food to customers without reported difficulties.

Karrissa D. argued the training period distinction was not supported by medical evidence, that pre-onset work history was irrelevant, that medical provider interactions were not analogous to workplace interactions, and that her Door Dash work actually supported more restrictive limits. The court rejected each argument. It noted that the RFC may be based on all relevant evidence, not just medical evidence (citing Masterson v. Barnhart, 363 F.3d 731 (8th Cir. 2004)), that pre-onset work history is relevant under federal regulations, that there is no categorical bar to considering medical provider interactions, and that the ALJ reasonably interpreted Door Dash evidence as supporting less restrictive limits.

Karrissa D. also argued the case Jason L. v. O'Malley, No. 23-184, 2024 WL 965240 (D. Minn. Mar. 6, 2024) was controlling precedent requiring remand. The court noted it is not bound by other district court decisions and distinguished Jason L. because in that case the ALJ failed to explain its deviation from the psychologist's superficial interaction limitation — whereas here the ALJ did explain the deviation.

Superficial vs. Occasional Interaction The court recognized that 'occasional' (referring to quantity of time with others) and 'superficial' (referring to quality/depth of interactions) are distinct terms. The reconsideration psychologist had recommended limiting Karrissa D. to brief and superficial interactions away from the public. The ALJ instead imposed an occasional public interaction limit, explaining that Karrissa D. socializes with friends and family, shops, and travels, making the occasional-contact limit 'more appropriate.'

Karrissa D. argued the ALJ improperly substituted one type of limit for another. The court found no error, holding that the same evidence about a claimant's real-world interactions naturally sheds light on both the quantity and quality of interactions she can handle. Because the ALJ acknowledged the psychologist's opinion, stated why a different limitation was more appropriate, and identified supporting evidence, the ALJ's decision was supported by substantial evidence.

Ruling Judge Tunheim: (1) overruled Karrissa D.'s objections; (2) adopted the R. & R.; (3) denied Karrissa D.'s request for relief; (4) granted the Commissioner's request for relief; and (5) affirmed the Commissioner's final decision denying benefits. Judgment was entered accordingly.