Keith H. v. Bisignano
- Donovan Frank
- 0:25-cv-02132
- U.S. District Court · District of Minnesota
- 6
In Keith H. v. Bisignano, Judge Frank dismissed with prejudice a Social Security disability appeal, finding substantial evidence supported the ALJ's denial of supplemental security income.
People who have applied for Social Security supplemental security income and been denied, particularly those with mental health impairments such as schizoaffective disorder or anxiety disorder, who are seeking federal court review of an ALJ's residual functional capacity determination.
What happened
In Keith H. v. Bisignano (Civil No. 25-2132), Keith H. sought judicial review of a Social Security Administration decision denying his application for supplemental security income. An Administrative Law Judge (ALJ) had found that Keith H. suffered from schizoaffective disorder, anxiety disorder, and substance use disorder, but concluded that he retained enough functional capacity to perform certain jobs available in the national economy and was therefore not disabled.
Keith H. argued that the ALJ wrongly found only moderate limitations in his ability to interact with others, contending that nearly every provider in the record supported a finding of marked (more severe) limitations. He challenged the ALJ's reliance on the opinion of psychological consultative examiner Dr. Dustin Warner, who found only moderate limitations but did not fully explain that finding in writing. Keith H. argued the ALJ should not have found Dr. Warner's opinion persuasive under these circumstances.
Judge Donovan W. Frank denied Keith H.'s request for relief and dismissed the complaint with prejudice. The court found that the ALJ's decision was supported by substantial evidence — a legal standard meaning enough evidence that a reasonable person could accept it as adequate, even if other conclusions might also be supportable. The court noted that Dr. Warner was not the only provider to identify moderate limitations, that the other two consultants reached the same conclusion, that Keith H.'s providers generally found him stable when taking medication, and that Dr. Warner had directly examined Keith H. and provided a recorded description of his examination. Because the record supported the ALJ's conclusion, the court affirmed the Commissioner's denial of benefits.
The detailed version
- Keith H. v. Bisignano · No. 0:25-cv-02132
- Donovan Frank
- June 25, 2026
Background
Keith H. applied for supplemental security income (SSI) in April
- Following two administrative hearings, an Administrative Law Judge (ALJ) denied his application on April 10,
- That decision became the Commissioner's final decision on March 28,
- Keith H. then filed a complaint in federal district court seeking judicial review, asking the court to reverse the denial and award benefits outright, or alternatively to remand (send back) the case to the agency for further proceedings.
The ALJ's Five-Step Analysis
The Social Security Administration uses a five-step sequential process to evaluate disability claims under 20 C.F.R. § 416.920(a)(4). At step two, the ALJ found Keith H. had three severe impairments: schizoaffective disorder, anxiety disorder, and substance use disorder. At step three, the ALJ found these impairments did not meet or equal any listing in the agency's Listing of Impairments — a catalog of conditions that automatically qualify as disabling.
Before reaching step four, the ALJ determined Keith H.'s residual functional capacity (RFC) — meaning the most he can still do despite his impairments. The ALJ found Keith H. capable of a full range of work at all exertional levels, subject to nonexertional (non-physical) limitations: he can understand, carry out, and persist in routine repetitive tasks; can engage in only superficial interactions with supervisors and co-workers; cannot perform customer or client service duties; and can adapt to the stressors of a routine repetitive work setting.
At step four, the ALJ found Keith H. could not perform his past relevant work. At step five, the ALJ found that jobs he could perform exist in significant numbers in the national economy, given his age, education, work experience, and RFC. The ALJ therefore concluded Keith H. was not disabled.
Legal Standard for Judicial Review
A federal court reviewing an ALJ's denial of benefits will affirm if the decision is supported by substantial evidence in the record as a whole and the ALJ made no legal error. 42 U.S.C. § 405(g). Substantial evidence is less than a preponderance (more likely than not) but enough that a reasonable mind could accept it as adequate to support the conclusion. Where substantial evidence supports two conflicting outcomes, the ALJ operates within a "zone of choice" and the court will not substitute its own judgment.
Keith H.'s Argument
Keith H. challenged only the ALJ's RFC determination, specifically the finding of only moderate limitations in interacting with others. He argued that every provider except psychological consultative examiner Dr. Dustin Warner supported a finding of marked (more severe) limitations, and that the ALJ improperly relied on Dr. Warner's opinion because Dr. Warner did not fully explain his finding of only moderate limitations.
The Court's Analysis
Judge Frank reviewed the administrative record and found the ALJ's decision supported by substantial evidence.
The court noted that an ALJ must determine RFC by reviewing all relevant evidence, including medical records, treating physician observations, and the claimant's own descriptions of limitations, but the burden is on the claimant to establish his RFC, and that RFC must be supported by some medical evidence.
The court observed that, as Keith H. himself acknowledged, the medical documentation of his impairments was generally sparse. The ALJ considered Keith H.'s testimony about difficulties interacting with others, but found that the objective medical evidence did not fully support the severity he described — a credibility determination to which courts defer. The ALJ found Keith H.'s providers generally described him as stable, particularly when taking medication.
Regarding Dr. Warner, the court acknowledged that Dr. Warner did not directly explain in writing his finding of moderate limitations, but noted he provided a telerecorded message describing his examination of Keith H., and that his conclusion was otherwise supported by the medical records. The ALJ found Dr. Warner's opinion generally persuasive based on his expertise, programmatic knowledge, and direct examination of Keith H.
Significantly, the court emphasized that Dr. Warner was not the only provider to find only moderate limitations — the two other psychological consultants reached the same conclusion (though the ALJ found their opinions only somewhat persuasive, apparently because they had not directly examined Keith H.). The combined weight of this evidence supported the ALJ's RFC finding.
Because the court found substantial evidence in the record to support the ALJ's RFC determination, it affirmed the Commissioner's final decision and declined to reweigh the evidence.
Disposition
The court denied Keith H.'s request for relief, granted the Commissioner's request for relief, and dismissed the complaint with prejudice.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.