Charity S. v. Bisignano
- Elizabeth Cowan Wright
- 0:25-cv-02629
- U.S. District Court · District of Minnesota
- 3
In Charity S. v. Bisignano, Judge Wright granted Charity S.'s request to reverse and remand the Social Security Commissioner's denial of disability benefits for further review.
People who have applied for Social Security disability benefits based on mental health conditions and whose claims were denied — particularly those whose ALJ decisions failed to adequately analyze variable mental health symptoms, dissociation, or memory impairments, or who received community support services that were used as evidence against their disability claims.
What happened
In Charity S. v. Frank Bisignano, Commissioner of Social Security (Case No. 25-cv-02629), Charity S. challenged the Social Security Administration's denial of her disability benefits application. An Administrative Law Judge (ALJ) had previously denied her benefits, and she asked the federal court to reverse that decision and send the case back for another look.
The court found problems with how the ALJ analyzed Charity S.'s mental health claims. Specifically, the ALJ failed to properly assess whether she met a specific mental health disability standard (called 'paragraph C' criteria), improperly discounted the opinions of her treating psychologist about dissociation and memory problems, and may have wrongly used the fact that she sought community support services as evidence she was more capable than claimed — without pointing to separate evidence actually supporting that conclusion.
Magistrate Judge Elizabeth Cowan Wright granted Charity S.'s request to reverse the Commissioner's decision and ordered the case sent back to the Social Security Administration. On remand, the agency must re-examine the paragraph C criteria, reconsider the treating psychologist's opinions, reassess Charity S.'s own statements about her symptoms, and revisit her Residual Functional Capacity — the agency's assessment of what work she can still do despite her limitations. The Commissioner's request to affirm the denial of benefits was denied.
The detailed version
- Charity S. v. Bisignano · No. 0:25-cv-02629
- Elizabeth Cowan Wright
- May 29, 2026
Background
Plaintiff Charity S. brought this action challenging the Social Security Administration's (SSA) denial of her disability benefits. The matter came before the court on Charity S.'s brief seeking reversal and remand (Dkt. 15) and the Commissioner's brief seeking affirmance (Dkt. 19). The court held an Announcement of Decision on May 29, 2026, and issued this written order the same day.
Issues Before the Court
The court identified four discrete errors in the ALJ's decision that warranted remand:
1. Paragraph C Criteria Analysis
Under the SSA's mental health disability listings, a claimant may qualify as disabled under "paragraph C" criteria if they require a highly structured setting or show only marginal adjustment — meaning difficulty adapting to the requirements of daily life or to changes in environment. The ALJ concluded at page 29 of the administrative record that there was "no evidence" of these criteria. The court found this analysis deficient because it did not consider the record as a whole regarding marginal adjustment and did not account for the variable nature of mental illness symptoms. The court cited Mabry v. Colvin, 815 F.3d 386, 392 (8th Cir. 2016), for the proposition that individuals with mental illness may experience periods during which they are relatively symptom-free, causing their functioning to vary significantly over time. The court also found the ALJ's paragraph C explanation insufficient to permit judicial review.
2. Discounting Treating Psychologist's Opinions
The ALJ discounted the opinions of Charity S.'s treating psychologist, Cheryl Sybesma Van Noord, PhD, regarding dissociation and memory impairments. The court found this problematic for two reasons. First, the ALJ failed to adequately consider specific record evidence — citing numerous administrative record entries — documenting Charity S.'s reported and observed dissociation and impaired memory. Second, the ALJ used Charity S.'s receipt of multiple community support services (including Adult Rehabilitative Mental Health Services, Nice Rooms Associate peer support services, Individualized Home Supports services, and Community Access for Disability Inclusion services) as evidence of her "persistence," "organizational acumen," and "ability to marshal resources" — implying she was more capable than claimed — without identifying any evidence beyond the mere fact that she received those services to support those characterizations.
3. Credibility of Plaintiff's Symptom Statements
The court ordered the Commissioner to reassess the weight given to Charity S.'s own statements about the intensity, persistence, and limiting effects of her mental health symptoms in light of the corrected analyses in items 1 and 2 above, and the full record.
4. Residual Functional Capacity (RFC)
The Residual Functional Capacity (RFC) is the SSA's assessment of the most a claimant can still do despite her limitations. The court ordered the Commissioner to revisit the RFC in light of the above corrections, and specifically to address whether the RFC should include limitations to 1-2 step tasks and superficial interactions — findings that both state agency reviewers and Dr. Van Noord had opined upon and that the ALJ had found persuasive (R. 34) — but which were apparently not incorporated into the RFC. If the Commissioner concludes those limitations should not be included, an explanation must be provided.
Disposition
Magistrate Judge Elizabeth Cowan Wright granted Charity S.'s brief (Dkt. 15) seeking reversal and remand, and denied the Commissioner's brief (Dkt. 19) seeking affirmance. The court ordered that judgment be entered accordingly and directed the Commissioner to address all four issues on remand.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.