Cramblitt v. Bisignano
- David Schultz
- 0:25-cv-00746
- U.S. District Court · District of Minnesota
- 5
In Charles A. C. v. Frank Bisignano, Commissioner of Social Security, Judge Blackwell upheld the denial of disability benefits to the plaintiff, ruling that the administrative law judge's decision to limit the plaintiff to 'superficial' interactions — rather than 'brief and superficial' as two agency psychologists recommended — was adequately explained and supported by the record.
Individuals who have been denied Social Security disability benefits and are challenging an ALJ's residual functional capacity determination, particularly where the ALJ's language differs from the terminology used by agency medical consultants.
What happened
In Charles A. C. v. Frank Bisignano, Commissioner of Social Security (Case No. 25-746), a Minnesota man sought federal court review of a Social Security Administration decision denying his application for disability benefits. The central dispute was whether the administrative law judge (ALJ) — the government official who initially decided the disability claim — made a legal error by limiting the plaintiff to 'superficial' interactions with others at work, rather than 'brief and superficial' interactions, as two agency psychologists had recommended. The plaintiff argued the ALJ failed to explain why the word 'brief' was dropped, and that the court's magistrate judge (a judicial officer who assists district judges) wrongly filled in that missing explanation.
The magistrate judge had issued a Report and Recommendation (R&R) recommending that the plaintiff's request to reverse or send the case back to the agency be denied, and that the agency's decision be upheld. The plaintiff objected to that recommendation. The court reviewed the objected-to portions of the R&R fresh, without deferring to the magistrate judge's conclusions, while reviewing the rest only for obvious error.
Judge Blackwell overruled the plaintiff's objection and accepted the R&R. The court found that the ALJ did, in fact, explain why the word 'brief' was omitted — the ALJ stated the term is not vocationally defined and chose more specific, policy-compliant language instead. The court also found that the ALJ's specific examples of permissible interactions (taking instructions, relaying information, and transferring material) were consistent with what the agency psychologists meant by 'brief and superficial,' and that the agency psychologists did not define 'brief' in a way that clearly conflicted with the ALJ's findings. The plaintiff's request to reverse or remand was denied, the defendant's request to affirm was granted, and the Commissioner's decision denying benefits was affirmed.
The detailed version
- Charles A. C. v. Frank Bisignano, Commissioner of Social Security, Civ. No. 25-746 (JWB/DTS), United States District Court, District of Minnesota
- Jerry W. Blackwell, United States District Judge
- October 7, 2025
Background
The plaintiff, Charles A. C., sought judicial review of the Social Security Administration's (SSA) denial of his disability benefits application. On August 6, 2025, Magistrate Judge David T. Schultz issued a Report and Recommendation (R&R) recommending that the plaintiff's motion to reverse or remand the agency's decision be denied and that the defendant Commissioner's motion to affirm be granted. The plaintiff timely objected to the R&R.
Standard of Review
The district court reviews de novo (anew, without deference to the lower decision) any portion of the R&R to which a party timely objects, pursuant to 28 U.S.C. § 636(b)(1) and District of Minnesota Local Rule 72.2(b)(3). Unobjected-to portions are reviewed only for clear error under Federal Rule of Civil Procedure 72(b).
The underlying ALJ decision is reviewed to determine whether it is supported by substantial evidence in the record as a whole and whether it adheres to applicable legal standards, citing Kraus v. Saul, 988 F.3d 1019, 1024 (8th Cir. 2021). An ALJ is not required to fully adopt medical opinions found persuasive, as long as an explanation is provided and the evidence supports the ALJ's findings. The ALJ's decision must have a 'logical bridge' between the evidence and conclusions, but need not address every possible limitation or piece of conflicting evidence.
The Objection
The plaintiff argued that the ALJ erred by finding him capable of 'superficial' interactions rather than 'brief and superficial' interactions as two agency psychologists opined, and that the R&R improperly supplied a post-hoc rationale for the ALJ's omission of the word 'brief.'
Court's Analysis
The court found that the ALJ did provide a reason for omitting 'brief' from the residual functional capacity (RFC) determination — the term is not vocationally defined, and the ALJ chose instead 'more specific, vocationally defined, and policy compliant language.' (A.R. 4024–25.) The ALJ also elaborated on what 'superficial' meant by giving specific examples: 'taking instructions, relaying information, and transferring material.' (A.R. 4017, 4025.)
The court cited Tria V. H. v. Colvin, Civ. No. 23-2979 (D. Minn. Jan. 10, 2025), which rejected a similar 'manufactured inconsistency' between an ALJ limiting a plaintiff to superficial interactions with those same types of examples and an agency psychologist who used 'very brief' and 'infrequent.' The court acknowledged the plaintiff's argument that Tria's reasoning was flawed because the example interactions do not necessarily imply brevity, but noted they do not necessarily imply extended duration either. The court found that the agency psychologists did not explain what they meant by 'brief and superficial' in a way clearly at odds with the ALJ's RFC finding, citing Jennifer L. v. Comm'r of Soc. Security, Civ. No. 23-1822 (D. Minn. Aug. 30, 2024).
The court further found that the ALJ assessed the agency psychologists' opinions and discussed other record evidence of the plaintiff's mental limitations and ability to interact with others — including longer-duration interactions and events post-dating the agency psychologists' opinions. Nothing in the record indicated the ALJ forgot the psychologists' opinions or deemed them irrelevant. The plaintiff's objection was overruled.
After reviewing unobjected-to portions of the R&R for clear error, the court found no clear error or legal error and accepted the R&R in full.
Disposition:
- Plaintiff's Objection (Doc. No. 19) — OVERRULED.
- The R&R (Doc. No. 17) — ACCEPTED.
- Plaintiff's request to reverse or remand (Doc. No. 14) — DENIED.
- Defendant's request to affirm the Commissioner's decision (Doc. No. 16) — GRANTED.
- The Commissioner's decision — AFFIRMED. Judgment to be entered accordingly.
Reviewer note from the AI+
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