Michael Lincoln v. Frank Bisignano - Social Security Disability Appeal
Summary
The Seventh Circuit affirmed the district court's decision upholding an Administrative Law Judge's denial of disability insurance benefits and supplemental security income to Michael Lincoln. Lincoln claimed disability beginning October 2019 due to prostate cancer and treatment-related fatigue. The court found substantial evidence supported the ALJ's residual functional capacity determination that Lincoln could perform light work with postural limitations and his past work as a school bus driver. The court rejected Lincoln's arguments that the ALJ improperly evaluated evidence regarding his cane use and subjective fatigue complaints, noting inconsistencies between Lincoln's allegations and the medical record.
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What changed
The Seventh Circuit upheld the Social Security Administration's denial of benefits by finding the ALJ's residual functional capacity determination was supported by substantial evidence. The court rejected Lincoln's challenge to how the ALJ weighed his cane use and fatigue complaints, noting medical records showed normal gait, minimal treatment for fatigue, and energy at baseline. The opinions of state agency medical consultants were found more persuasive than the treating nurse practitioner who assessed greater limitations. For similarly situated disability claimants, this decision reinforces that treating physicians' opinions can be discounted when inconsistent with objective medical evidence and when based primarily on subjective complaints rather than clinical findings.
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April 23, 2026 Get Citation Alerts Download PDF Add Note
Michael Lincoln v. Frank Bisignano
Court of Appeals for the Seventh Circuit
- Citations: None known
- Docket Number: 24-2668
Judges: Pryor
Combined Opinion
by Pryor
In the
United States Court of Appeals
For the Seventh Circuit
No. 24-2668
MICHAEL LINCOLN,
Plaintiff-Appellant,
v.
FRANK BISIGNANO, 1 Commissioner of Social Security,
Defendant-Appellee.
Appeal from the United States District Court for the
Central District of Illinois.
No. 23-cv-01177 — Jonathan E. Hawley, Judge.
ARGUED MAY 14, 2025 — DECIDED APRIL 23, 2026
Before SYKES, JACKSON-AKIWUMI and PRYOR, Circuit Judges.
PRYOR, Circuit Judge. Michael Lincoln applied for disability
insurance benefits and supplemental security income, alleg-
ing disability beginning in October 2019. An administrative
law judge (ALJ) found Lincoln was not disabled upon
1 Frank Bisignano replaced Leland Dudek as Commissioner of the Social
Security Administration and is substituted as the defendant-appellee. See
FED. R. APP. P. 43(c)(2).
2 No. 24-2668
concluding that his residual functional capacity (RFC) 2 would
allow him to perform his past work as a school bus driver.
The district court affirmed.
On appeal, Lincoln challenges the ALJ’s RFC determina-
tion, arguing the ALJ failed to properly evaluate evidence per-
taining to Lincoln’s use of a cane and fatigue. Because sub-
stantial evidence supports the ALJ’s decision, we affirm.
I. BACKGROUND
In his application for disability insurance benefits and
supplemental security income disability benefits, Lincoln
claimed that conditions including prostate cancer limited his
ability to work. Lincoln began treatment for cancer in Novem-
ber 2019, including chemotherapy, hormonal therapy (also re-
ferred to as Lupron injections or androgen deprivation ther-
apy), and radiation beam therapy. He concluded radiation
beam therapy roughly six months later, in May 2020. By the
following month, Lincoln’s prostate-specific antigen (PSA)
levels, which signal the presence of prostate cancer, were un-
detectable. Lincoln continued to receive Lupron injections
every six months through May 2021. Lincoln’s prostate cancer
was in remission.
On May 25, 2022, ALJ Michael Hellman held a hearing on
Lincoln’s application and on August 3, 2022, found Lincoln
was not disabled.
2 “Residual functional capacity (‘RFC’) is an assessment of an individual’s
ability to do sustained work.” Jarnutowski v. Kijakazi, 48 F.4th 769, 773 (7th
Cir. 2022). “It is the most an individual can work despite his or her limita-
tions or restrictions.” Id.
No. 24-2668 3
The ALJ reasoned that Lincoln had the residual functional
capacity to perform “light work” with certain postural limita-
tions, including that he could “occasionally climb ramps or
stairs; never climb ropes, ladders, and scaffolds; frequently
balance and stoop; and occasionally kneel, crouch, and
crawl.” This RFC, in conjunction with testimony from Lincoln
and a vocational expert, allowed the ALJ to conclude that Lin-
coln was able to perform his past work as a school bus driver
at the light exertional level.
In “reducing” Lincoln’s RFC to “light work with addi-
tional postural limitations,” the ALJ found relevant Lincoln’s
reports of daily fatigue stemming from his cancer treatments,
as well as complaints of back and hip pain. At the same time,
the ALJ decided against “rely[ing] heavily” on Lincoln’s sub-
jective complaints because Lincoln’s statements about the “in-
tensity, persistence and limiting effects” of his symptoms
were “not entirely consistent” with other evidence in the rec-
ord. For instance, the ALJ noted that despite Lincoln’s allega-
tions of fatigue, Lincoln engaged in various activities of daily
living and received “minimal” treatment for fatigue. Moreo-
ver, the ALJ found probative notes from various medical ap-
pointments in 2020 and 2021. These notes included observa-
tions that Lincoln reported feeling “well” overall; that Lincoln
had a “little bit of fatigue” but “no significant difficulties”;
that Lincoln’s report of fatigue was “somewhat nonspecific”;
and that Lincoln reported his energy being at “baseline.”
The ALJ also determined that there was “no indication”
that Lincoln required a cane “on an ongoing basis.” While the
ALJ acknowledged Lincoln used a cane during some exami-
nations, the ALJ observed that in August 2020, Lincoln re-
ported using a cane “only occasionally” and was able to walk
4 No. 24-2668
greater than 50 feet without support; in November 2021, Lin-
coln had a “normal” gait and no gross motor deficits; in De-
cember 2021, Lincoln’s primary care physician encouraged
him to move as much as possible and recommended physical
therapy while declining to provide him a handicap parking
placard because he would not yet qualify; in January 2022,
Lincoln briefly used a walker following a medical procedure;
and in March 2022, Lincoln had a full range of motion despite
an abnormal gait and cane use.
Medical opinions also informed the RFC determination.
The ALJ found “substantially persuasive” the opinions of
state agency medical consultants, which the ALJ observed
were consistent with one another. Those opinions included
findings that Lincoln could occasionally lift 20 pounds, fre-
quently lift 10 pounds, stand or walk for about six hours in an
eight-hour workday, and sit for a total of six hours in an eight-
hour workday.
In contrast, the ALJ found “only partly persuasive” an Au-
gust 2020 opinion of Advanced Practice Nurse Alisha Jack-
son, who had treated Lincoln. Nurse Jackson concluded that
Lincoln’s physical limitations were much greater. For in-
stance, she opined that Lincoln had pain so constantly severe
that it impaired his ability to perform “even simple work
tasks”; could walk only one city block without resting or ex-
periencing severe pain; needed to stand after one hour of sit-
ting and could stand for only 30 minutes before needing to sit
or walk; could not sit for more than two hours total in a work-
day; could not stand or walk for more than two hours total in
a workday; could never lift more than 20 pounds; and needed
a cane when walking or standing. In deeming Nurse Jackson’s
opinion only partly persuasive, the ALJ found it important
No. 24-2668 5
that the opinion seemed “based solely on [Lincoln’s] com-
plaints and nothing objective,” was issued within twelve
months after the alleged onset date of Lincoln’s disability, and
was “overall not fully supported and not consistent with
other opinions of record.”
The ALJ ultimately denied Lincoln’s application. Alt-
hough the ALJ found Lincoln suffered from prostate cancer
(now in remission), lumbar spondylosis, and obesity, he re-
tained the RFC to perform light work with certain postural
limitations. See 20 C.F.R. §§ 404.1520 (a)(4) and 416.920(c). In
light of this RFC, the ALJ concluded that Lincoln could return
to his past work as a school bus driver at the light exertional
level. As such, Lincoln was found not disabled at any time
from the alleged onset date through the date of the decision.
The Appeals Council denied further administrative review,
making the ALJ’s decision the final decision of the Commis-
sioner. On judicial review, the district court affirmed the
ALJ’s denial of benefits. This appealed followed.
II. DISCUSSION
On appeal, Lincoln challenges the ALJ’s determination
that he was capable of performing light work, and thus not
entitled to disability benefits or supplemental security in-
come. He contends the ALJ failed to properly account for the
severity of his fatigue and his need for a cane. Also, he main-
tains the ALJ failed to support the decision to “partly” credit
the opinion of Lincoln’s primary care provider, Nurse Jack-
son. We will discuss each of these arguments in turn.
“We review de novo the district court’s affirmance of the
ALJ’s decision and review directly the decision of the ALJ.”
Butler v. Kijakazi, 4 F.4th 498, 501 (7th Cir. 2021). “We will
6 No. 24-2668
reverse the decision of an ALJ only if it is based on incorrect
legal standards or unsupported by substantial evidence.”
Baptist v. Kijakazi, 74 F.4th 437, 441 (7th Cir. 2023). And the
threshold for “substantial evidence” is low, requiring only
“such relevant evidence as a reasonable mind might accept as
adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S.
97, 103 (2019) (internal quotation and citation omitted). Under
this deferential standard, “[w]e will not reweigh the evidence,
resolve debatable evidentiary conflicts, determine credibility,
or substitute our judgment for the ALJ’s determination so
long as substantial evidence supports it.” Gedatus v. Saul, 994
F.3d 893, 900 (7th Cir. 2021). However, “we conduct a critical
review because [the ALJ’s] decision cannot stand if it lacks ev-
identiary support or an adequate discussion of the issues.”
Moy v. Bisignano, 142 F.4th 546, 552 (7th Cir. 2025) (internal
quotation and citation omitted). In other words, the ALJ must
provide a logical bridge from the evidence to his conclusion.
Id.
A claimant proves disability by showing “that he or she ‘is
unable to engage in any substantial gainful activity by reason
of any medically determinable physical or mental impairment
which can be expected to result in death or which has lasted
or can be expected to last for a continuous period of not less
than twelve months.’” Chavez v. O’Malley, 96 F.4th 1016, 1021
(7th Cir. 2024) (quoting 42 U.S.C. § 1382c(a)(3)(A)). The
“claimant bears the burden of proving their disability.” Thorl-
ton v. King, 127 F.4th 1078, 1080 (7th Cir. 2025).
ALJs use a five-step analytical process to determine
whether a claimant is eligible for benefits on the basis of dis-
ability. They consider whether “(1) the claimant is presently
employed; (2) the claimant has a severe impairment or
No. 24-2668 7
combination of impairments; (3) the claimant’s impairment
meets or equals any impairment listed in the regulations as
being so severe as to preclude substantial gainful activity;
(4) the claimant’s residual functional capacity leaves him un-
able to perform his past relevant work; and (5) the claimant is
unable to perform any other work existing in significant num-
bers in the national economy.” Butler, 4 F.4th at 501 (internal
quotation and citation omitted).
At issue here is step four, which encompasses the ALJ’s
assessment of Lincoln’s RFC. At bottom, Lincoln maintains
that the ALJ’s RFC finding failed to properly account for the
severity of his fatigue and his need for a cane. First, we ad-
dress Lincoln’s arguments that the ALJ erred in evaluating
certain medical records and Lincoln’s reported symptoms.
We then turn to Lincoln’s contention that the ALJ should have
credited to a greater degree the opinion of Nurse Alisha Jack-
son, who concluded that Lincoln’s fatigue and cane usage
would cause significant interference with Lincoln’s ability to
carry out simple work tasks.
A. ALJ’s Assessment of Lincoln’s Medical Records and
Symptoms
Lincoln asserts that the ALJ failed to properly account for
Lincoln’s need for a cane and fatigue by overlooking or mis-
characterizing relevant evidence and patently erring in as-
sessing Lincoln’s reported symptoms.
1. Cane Use
Lincoln argues the ALJ overlooked medical records from
the spring and summer of 2021 which observed that Lincoln
used a cane, as well as a note from a March 2022 medical ap-
pointment reflecting that Lincoln reported always using a
8 No. 24-2668
cane. He characterizes the record as showing worsening bal-
ance over time and complete dependence on a cane by 2021.
In Lincoln’s view, omitting discussion of these facts violated
Social Security Ruling 96-8p, which requires an ALJ to look at
all relevant evidence, and led the ALJ to render a decision
“based on an incomplete picture of the evidence.”
We disagree and find supported by substantial evidence
the ALJ’s determination that Lincoln did not require a cane on
an ongoing basis. Although Lincoln cites portions of the rec-
ord indicating he increasingly used a cane in the spring and
summer of 2021 and in 2022, the ALJ assessed that same evi-
dence in the same timeframe and weighed it differently. The
ALJ concluded the evidence reflected that Lincoln did not al-
ways require a cane. Specifically, the ALJ noted that in No-
vember 2021, Lincoln’s gait was normal; and in December
2021, Lincoln’s primary care physician denied Lincoln a
handicap parking placard because he would not yet qualify.
The ALJ could reasonably conclude from these facts, along
with records from earlier in time which reported that Lincoln
could walk more than 50 feet without support and only “oc-
casionally” used a cane, that Lincoln’s use of a cane was not
ongoing during the time he alleged disability.
Finding otherwise would require us to “reweigh the evi-
dence” on appeal, which we are unable to do. See Jarnutowski
v. Kijakazi, 48 F.4th 769, 773 (7th Cir. 2022). And to the extent
Lincoln suggests the ALJ was required to independently dis-
cuss each of the medical records he cites on appeal, we stress
that an ALJ “need not address every piece or category of evi-
dence identified by a claimant, fully summarize the record, or
cite support for every proposition or chain of reasoning.”
Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024).
No. 24-2668 9
Ultimately, what matters is that the ALJ based his decision on
such evidence that a reasonable mind could find adequate to
support the ALJ’s conclusion. Jarnutowski, 48 F.4th at 773.
2. Fatigue
Lincoln further argues that the ALJ did not adequately ac-
count for his fatigue. In particular, he asserts that the ALJ dis-
counted the severity of his fatigue by improperly finding that
he was not undergoing any “specific” treatment for his fa-
tigue; concluding that his fatigue complaints were “occa-
sional” rather than “frequent” or “repeated”; and failing to
“contemplate” that fatigue resulting from his cancer care con-
tinued even after the conclusion of his course of treatment. He
also maintains that the ALJ failed to provide a “logical
bridge” linking the ALJ’s observations of Lincoln’s fatigue to
the conclusion that Lincoln would be able to perform light
work.
Substantial evidence supported the ALJ’s decision that
light work was appropriate despite Lincoln’s reports of “daily
fatigue.” The ALJ cited evidence indicating Lincoln’s fatigue
was present but not debilitating. The ALJ noted that Lincoln
testified he was able to perform activities of daily living; that
a provider found Lincoln’s report of fatigue “somewhat non-
specific” and recommended that he maintain as active of a
lifestyle as possible; and that medical providers’ notes from
May 2020 and May 2021 indicated Lincoln’s energy was at
“baseline” or that he had “a little bit of fatigue” but no “sig-
nificant difficulties.” This evidence does not compel a finding
that Lincoln’s fatigue required greater restrictions in his RFC.
Instead, the ALJ’s discussion of fatigue connects logically to
the ALJ’s conclusion to “reduce” Lincoln to light work rather
than find Lincoln able to work at a greater level of intensity.
10 No. 24-2668
Where we have found an ALJ failed to satisfy the “logical
bridge” requirement, the evidence cited by the ALJ had “little
or no apparent bearing” on the ALJ’s conclusion. Lothridge v.
Saul, 984 F.3d 1227, 1233 (7th Cir. 2021); see also Moy,
142 F.4th at 554. Because the facts cited by the ALJ logically
bear on the degree to which Lincoln’s fatigue limited his abil-
ities, we disagree with Lincoln’s position that the ALJ failed
to create a logical bridge to connect the evidence to his con-
clusions.
While we recognize the ALJ could have provided more de-
tail concerning his evaluation of Lincoln’s testimony, we re-
view the ALJ’s discussion of the evidence holistically. See Zell-
weger v. Saul, 984 F.3d 1251, 1252, 1255 (7th Cir. 2021). When
viewing the decision in its entirety, it is clear the ALJ consid-
ered Lincoln’s testimony, negating the need for a reversal on
this ground.
We also decline to remand this case based on the ALJ’s ob-
servation that Lincoln did not receive “specific treatment” for
his fatigue, or the ALJ’s description of the fatigue reports as
“occasional” rather than frequent. The ALJ’s conclusion that
that Lincoln received only “minimal treatment during the pe-
riod at issue” is supported by the fact that providers recom-
mended Lincoln maintain a healthy lifestyle to combat fa-
tigue. The ALJ reasonably concluded that such lifestyle rec-
ommendations did not constitute “specific” treatment and
that the absence of more intensive treatment indicated the fa-
tigue did not warrant a more restrictive RFC. Likewise, char-
acterizing Lincoln’s fatigue reports as “occasional” was not
patently wrong, particularly given that the ALJ factored into
the RFC determination an observation that Lincoln experi-
enced fatigue “daily.” See Hess v. O’Malley, 92 F.4th 671, 679
No. 24-2668 11
(7th Cir. 2024) (“We will overturn the ALJ’s evaluation of a
claimant’s subjective symptoms only if it is patently wrong,
which means that the decision lacks any explanation or sup-
port.” (internal quotation and citation omitted)).
Ultimately, this is not a case where the ALJ overlooked en-
tire swaths of evidence or selectively discussed the evidence;
the ALJ acknowledged that Lincoln at times used a cane and
expressly factored Lincoln’s fatigue into the RFC determina-
tion. See Reinaas v. Saul, 953 F.3d 461, 466 (7th Cir. 2020) (ALJs
cannot cherry-pick facts while overlooking “entire swaths” of
evidence to the contrary); Campbell v. Astrue, 627 F.3d 299, 306
(7th Cir. 2010) (ALJs may not “selectively discuss” the record).
Instead, Lincoln essentially asks this Court to reweigh the rec-
ord evidence: favoring evidence of his cane use and elevated
fatigue levels, and disfavoring evidence of his normal gait
and movements, baseline energy levels, report of “little” fa-
tigue, and engagement in daily activities. Because we are fore-
closed from substituting our judgment for the ALJ’s when the
decision is supported by substantial evidence, Gedatus, 994
F.3d at 900, we cannot find Lincoln’s arguments warrant re-
versal.
B. ALJ’s Assessment of Nurse Jackson’s Opinion
Lincoln also takes issue with the ALJ’s characterization of
Nurse Jackson’s August 2020 opinion as only “partly persua-
sive.” The ALJ concluded that Nurse Jackson’s opinion was
“overall not fully supported,” was inconsistent with other
opinions of record, and seemed “based solely on [Lincoln’s]
complaints and nothing objective.” Lincoln asserts the ALJ
erred because Nurse Jackson’s opinion was supported by her
12 No. 24-2668
treatment notes and was consistent with evidence from other
treating sources. Had the ALJ properly analyzed Nurse Jack-
son’s opinion, Lincoln suggests the ALJ would have found
Lincoln did require a cane and his symptoms interfered with
this ability to perform light work.
“[A]n ALJ must ‘evaluate the persuasiveness’” of a medi-
cal opinion provided by a medical source “for its ‘supporta-
bility’ and ‘consistency.’” Jones v. Dudek, 134 F.4th 991, 994
(7th Cir. 2025) (quoting 20 C.F.R. §§ 404.1520c(a), 416.920c(a)).
“The more relevant the objective medical evidence and sup-
porting explanations presented by a medical source are to
support his or her medical opinion(s) … the more persuasive
the medical opinions … will be.” 20 C.F.R. § 404.1520c(c)(1).
Likewise, “[t]he more consistent a medical opinion[] … is
with the evidence from other medical sources and nonmedi-
cal sources in the claim, the more persuasive the medical
opinion[] … will be.” Id. § 404.1520c(c)(2).
Because the ALJ’s analysis of consistency and supportabil-
ity in relation to Nurse Jackson’s opinion was adequate, we
do not find reversal warranted. The ALJ concluded Nurse
Jackson’s opinion was “not fully supported” after observing
the opinion “seem[ed] to [be] based solely on the claimant’s
complaints” rather than “objective” evidence. Lincoln’s argu-
ments do not show error in this reasoning. To the extent Lin-
coln argues Nurse Jackson’s opinion was in fact supported by
objective measures, Lincoln does not explain how the objec-
tive measures to which he points bear on his ability to move
and work. For instance, he does not explain why Nurse Jack-
son’s treatment notes concerning his PSA level and biopsy re-
sult informed Nurse Jackson’s conclusions about his need for
a cane or ability to sit or stand.
No. 24-2668 13
The ALJ also analyzed consistency when observing that
Nurse Jackson’s opinion was inconsistent with other opinions
in the record. While Lincoln urges that inconsistency with
state agency opinions should not alone be a reason to find less
persuasive Nurse Jackson’s opinion, the ALJ did not reach its
persuasiveness determination on that sole basis. Rather, the
ALJ also emphasized that Nurse Jackson’s opinion was not
supported by objective measures and was issued close in time
to the alleged disability onset date.
III. CONCLUSION
Because the ALJ provided a “logical bridge” from the evi-
dence to his RFC determination, we AFFIRM.
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