Karla P. v. Bisignano
- Jeffrey Bryan
- 0:24-cv-04348
- U.S. District Court · District of Minnesota
- 6
In Karla P. v. Frank Bisignano, Commissioner of Social Security, Judge Jeffrey M. Bryan denied Karla P.'s appeal and upheld the Social Security Administration's decision that she was not entitled to disability benefits, finding that the administrative law judge's definition of 'superficial' workplace interaction as equivalent to a people rating of '7' or '8' in the Dictionary of Occupational Titles was supported by substantial evidence.
Individuals who have been denied Social Security disability benefits (SSI or DIB) and whose ALJ decisions included residual functional capacity limitations described as 'superficial' workplace interaction defined by reference to Dictionary of Occupational Titles people rating codes of '7' or '8.'
What happened
In Karla P. v. Frank Bisignano, Commissioner of Social Security (Case No. 24-CV-4348), Karla P. applied for Supplemental Security Income (SSI) and Disability Insurance Benefits (DIB), claiming she was disabled under the Social Security Act. An administrative law judge (ALJ) reviewed her claim — considering conditions including kidney disease, degenerative disc disease of the cervical spine, obesity, major depressive disorder, generalized anxiety disorder, and adjustment disorder — and concluded through a required five-step evaluation process that she retained the ability to perform light work with certain limitations, including only brief and superficial interaction with supervisors and coworkers. The ALJ therefore found her not disabled and denied her benefits.
Karla P. appealed to federal court, and a magistrate judge (a judicial officer who assists the district court) issued a Report and Recommendation suggesting that her appeal be denied. Karla P. objected, arguing specifically that the ALJ improperly and arbitrarily equated 'superficial' interaction with a people rating of '7' or '8' from the Dictionary of Occupational Titles (DOT), a reference guide used to classify jobs by the type and level of human interaction they require. She contended the ALJ failed to explain how those DOT ratings matched a restriction to superficial contact, and that the connection was unsupported.
Judge Jeffrey M. Bryan overruled Karla P.'s objection and adopted the magistrate judge's recommendation, denying her request to reverse or send the case back to the Social Security Administration. The court found that the ALJ's equation of 'superficial' interaction with DOT people ratings of '7' or '8' — the two lowest levels of human interaction in that system — was consistent with prior rulings from this district and the Eighth Circuit Court of Appeals, and was supported by substantial evidence (meaning enough evidence for a reasonable person to agree with the conclusion). The case was dismissed.
The detailed version
Case: Karla P. v. Frank Bisignano, Commissioner of Social Security, No. 24-CV-4348 (JMB/DLM), United States District Court for the District of Minnesota. Decided March 24, 2026, by Judge Jeffrey M. Bryan.
Background and Administrative History Karla P. applied for Supplemental Security Income (SSI) and Disability Insurance Benefits (DIB) under the Social Security Act, claiming disability. An administrative law judge (ALJ) conducted a hearing and evaluated her claim under the standard five-step sequential evaluation framework set out at 20 C.F.R. § 404.1520(a)(4)(i)–(v). At step one, the ALJ found Karla P. had not engaged in substantial gainful activity since her application date. At step two, the ALJ identified severe impairments: degenerative disc disease of the cervical spine, hypertension, obesity, left distal clavicle osteolysis, major depressive disorder, generalized anxiety disorder, and adjustment disorder. At step three, the ALJ found her impairments did not meet or equal any listed impairment under 20 C.F.R. Part 404, Subpart P, Appendix 1. At step four, the ALJ assessed a residual functional capacity (RFC — the most a claimant can do despite her limitations) to perform light work with nonexertional limitations, including restriction to 'brief and superficial interaction with supervisors/co-workers meaning, the 5th digit of the DOT code is a '7' or '8.'' At step five, the ALJ found Karla P. could perform available jobs in the national economy. The ALJ concluded she was not disabled and denied benefits.
Magistrate Judge's Report and Recommendation Karla P. sought judicial review in district court. United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) on January 5, 2026, recommending denial of Karla P.'s appeal. Karla P. timely objected.
Karla P.'s Objection Karla P. did not challenge the multiple medical opinions in the record restricting her to superficial interaction with coworkers and supervisors. Instead, she argued the ALJ failed to explain how 'superficial' equated to DOT people ratings of '7' or '8,' and characterized this equation as 'entirely arbitrary.' The Dictionary of Occupational Titles (DOT) uses a fifth-digit code to rate the level of human interaction a job requires, ranging from '0' (Mentoring — highest complexity) through '8' (Taking Instructions-Helping — lowest complexity). A rating of '7' (Serving) involves attending to needs or requests of people with immediate response; a rating of '8' (Taking Instructions-Helping) involves attending to work assignment instructions from a supervisor with no immediate response required unless clarification is needed.
Court's Analysis Judge Bryan conducted a de novo review (independent re-examination) of the record under 42 U.S.C. § 405(g), applying the substantial evidence standard — defined as less than a preponderance of the evidence but enough for a reasonable mind to find adequate support for the ALJ's conclusion. The court noted it cannot substitute its own judgment for the ALJ's or disturb the ALJ's credibility determinations or weighing of conflicting evidence. Citing prior decisions from within the District of Minnesota and the Eighth Circuit, the court rejected Karla P.'s argument as a 'manufactured inconsistency.' Specifically, the court cited Katie R. v. O'Malley, No. 23-CV-1139 (PAM/DLM), 2024 WL 1050822 (D. Minn. Mar. 11, 2024), affirmed by the Eighth Circuit in Rygmyr v. Dudek, No. 24-2005, 2025 WL 1143244 (8th Cir. Apr. 18, 2025), and Julie P. v. O'Malley, No. 23-CV-2980 (LMP/ECW), 2024 WL 4880375 (D. Minn. Nov. 25, 2024), among others. The court acknowledged that the DOT cautions its 'People' levels 'can be considered a hierarchy only in the most general sense' (citing Tiffany B. v. Kajakazi, No. 22-CV-1227, 2023 WL 3958424 (D. Minn. May 22, 2023)), but concluded that a rating of '8' still represents the lowest possible level of human interaction in the labor force, making the ALJ's equation reasonable and consistent with substantial evidence.
Disposition The court: (1) overruled Karla P.'s objection to the R&R; (2) adopted the R&R; (3) denied Karla P.'s request to reverse or remand the Commissioner's decision; (4) granted the Commissioner's request to affirm the decision; and (5) dismissed the case. Judgment was ordered to be entered accordingly.
Reviewer note from the AI+
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