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Feb. 25, 2026 Get Citation Alerts Download PDF Add Note

Madyanatuddiyn D. v. Frank Bisignano, Commissioner of Social Security

District Court, N.D. Illinois

• Citations: None known
• Docket Number: 1:25-cv-05255

• Precedential Status: Unknown Status

• Opinion

• Authorities (10)

• Cited By (0)

• Summaries (0)

• Similar Cases (0)

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Trial Court Document

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

MADYANATUDDIYN D.,1 )

)

Plaintiff, )

) No. 25 C 5255

v. )

) Magistrate Judge

FRANK BISIGNANO, ) Daniel P. McLaughlin

Commissioner of Social Security, )

)

Defendant. )

)

         MEMORANDUM OPINION AND ORDER                               

This action was brought under 42 U.S.C. § 405 (g) to review the final decision
of the Commissioner of Social Security denying Plaintiff Madyanatuddiyn D.’s
claims for Disability Insurance Benefits (“DIB”) and Supplemental Security Income
(“SSI”). The parties have consented to the jurisdiction of the United States
Magistrate Judge pursuant to 28 U.S.C. § 636 (c). For the reasons that follow,
Plaintiff’s motion for summary remand [16] is granted, and the Commissioner’s
cross-motion for summary judgment [17] is denied.

1 In accordance with Internal Operating Procedure 22 – Privacy in Social Security
Opinions, the Court refers to Plaintiff only by her first name and the first initial of her last
name.

BACKGROUND

I. PROCEDURAL HISTORY

On November 20, 2019, Plaintiff filed claims for DIB and SSI, alleging

disability since October 28, 2018. Following a hearing, an Administrative Law
Judge (“ALJ”) issued an unfavorable decision on April 1, 2020. Following an appeal,
and pursuant to an agreed remand, the United States District Court for the
Northern District of Illinois remanded the matter for further administrative
proceedings on March 21, 2022. The ALJ held a telephonic remand hearing on
August 21, 2023, and all participants attended the hearing by telephone. Plaintiff

appeared and testified at the hearing and was represented by counsel. A vocational
expert (“VE”) also testified.

On April 3, 2024, the ALJ again denied Plaintiff’s claims for benefits, finding
her not disabled under the Social Security Act. The Social Security Administration
Appeals Council then denied Plaintiff’s request for review, leaving the ALJ’s April
3, 2024 decision as the final decision of the Commissioner and, therefore, reviewable
by the District Court under 42 U.S.C. § 405 (g). See Haynes v. Barnhart, [416 F.3d

621, 626](https://www.courtlistener.com/opinion/791178/richard-haynes-v-jo-anne-b-barnhart-commissioner-of-social-security/#626) (7th Cir. 2005).

II. ALJ DECISION

In the ALJ’s April 3, 2024 decision, Plaintiff’s claims were analyzed in
accordance with the five-step sequential evaluation process established under the
Social Security Act. See 20 C.F.R. § 404.1520 (a)(4). The ALJ found at step one that
Plaintiff engaged in substantial gainful activity throughout 2018 and 2019.
However, the ALJ further determined that there had been a continuous 12-month
period during which Plaintiff did not engage in substantial gainful activity. At step
two, the ALJ concluded that Plaintiff had the following severe impairments: obesity;

lumbar degenerative joint disease; migraine headaches; carpal tunnel syndrome;
anxiety; and depression. The ALJ concluded at step three that Plaintiff’s
impairments, alone or in combination, do not meet or medically equal any listed
impairments.

Before step four, the ALJ determined that Plaintiff retained the residual
functional capacity (“RFC”) to perform sedentary work with the following additional

limitations: occasional climbing of ramps or stairs; no climbing of ladders, ropes, or
scaffolds; occasional balancing, stooping, kneeling, crouching, or crawling; frequent
fine manipulation bilaterally; no concentrated exposure to loud noise environments;
no concentrated exposure to hazards such as dangerous machinery or unprotected
heights; can focus and persist in the performance of simple, routine tasks; and can
perform work involving occasional changes and occasional decision-making. At step
four, the ALJ concluded that Plaintiff would be unable to perform her past relevant

work as a home health provider. However, at step five, based upon the VE’s
testimony and Plaintiff’s age, education, work experience, and RFC, the ALJ found
that Plaintiff can perform jobs existing in significant numbers in the national
economy, leading to a finding that she is not disabled under the Social Security Act.
DISCUSSION

I. ALJ LEGAL STANDARD

Under the Social Security Act, a person is disabled if she has an “inability 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.” 42 U.S.C. § 423 (d)(1)(a). In order to determine whether a plaintiff is
disabled, the ALJ considers the following five questions in order: (1) Is the plaintiff
presently unemployed? (2) Does the plaintiff have a severe impairment? (3) Does

the impairment meet or medically equal one of a list of specific impairments
enumerated in the regulations? (4) Is the plaintiff unable to perform her former
occupation? and (5) Is the plaintiff unable to perform any other work? 20 C.F.R. §
416.920 (a)(4).

An affirmative answer at either step three or step five leads to a finding that
the plaintiff is disabled. Young v. Sec’y of Health & Human Servs., 957 F.2d 386,
389 (7th Cir. 1992). A negative answer at any step, other than at step three,

precludes a finding of disability. Id. The plaintiff bears the burden of proof at steps
one to four. Id. Once the plaintiff shows an inability to perform past work, the
burden then shifts to the Commissioner to show the plaintiff’s ability to engage in
other work existing in significant numbers in the national economy. Id. II. JUDICIAL REVIEW

Section 405(g) provides in relevant part that “[t]he findings of the
Commissioner of Social Security as to any fact, if supported by substantial evidence,

shall be conclusive.” 42 U.S.C. § 405 (g). Judicial review of the ALJ’s decision is thus
limited to determining whether the ALJ’s findings are supported by substantial
evidence or based upon legal error. Clifford v. Apfel, 227 F.3d 863, 869 (7th Cir.
2000); Stevenson v. Chater, 105 F.3d 1151, 1153 (7th Cir. 1997). Substantial
evidence is “such relevant evidence as a reasonable mind might accept as adequate
to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971); Skinner v.

Astrue, 478 F.3d 836, 841 (7th Cir. 2007). An ALJ’s decision should be affirmed even
in the absence of overwhelming evidence in support: “whatever the meaning of
‘substantial’ in other contexts, the threshold for such evidentiary sufficiency is not
high. Substantial evidence is . . . ‘more than a mere scintilla.’ . . . It means – and
means only – ‘such relevant evidence as a reasonable mind might accept as
adequate to support a conclusion.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154, (2019)
(citations omitted).

The Seventh Circuit has made clear that ALJs are “subject to only the most
minimal of articulation requirements” and “need not address every piece or category
of evidence 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-
54 (7th Cir. 2024) (citations omitted). All that is required is that “ALJs provide an
explanation for how the evidence leads to their conclusions that is sufficient to allow
. . . a reviewing court[] to assess the validity of the agency’s ultimate findings and
afford [the appellant] meaningful judicial review.” Id. at 1054 (citations and
internal quotations omitted). Where conflicting evidence would allow reasonable

minds to differ, the responsibility for determining whether a plaintiff is disabled
falls upon the Commissioner, not the court. See Herr v. Sullivan, 912 F.2d 178, 181 (7th Cir. 1990). This Court may not substitute its judgment for that of the
Commissioner by reevaluating facts, reweighing evidence, resolving conflicts in
evidence, or deciding questions of credibility. Skinner, 478 F.3d at 841; see also
Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008) (holding that the ALJ’s decision

must be affirmed even if “‘reasonable minds could differ’” as long as “the decision is
adequately supported”) (citation omitted).

III. ANALYSIS

Plaintiff argues that the ALJ’s decision was in error for several reasons,
including: (1) the ALJ’s RFC assessment was incomplete and unsupported by
substantial evidence; and (2) the ALJ improperly discounted Plaintiff’s subjective
allegations.

In advancing her first argument, Plaintiff contends, inter alia, that the ALJ
failed to properly consider her asserted difficulties with sitting and/or her need for a
sit/stand option. ([16] at 8-9.) Pertinent to that argument, the ALJ determined in
his prior decision that Plaintiff could not sit for longer than 4 hours at a time and
would need a sit/stand option. (R. 23.) In his instant decision, the ALJ noted that
Plaintiff alleged difficulty with sitting and “testified she is unable to walk, stand, or
sit for long.” (Id. at 1152.) The ALJ further acknowledged Plaintiff’s primary care
physician’s opinion that Plaintiff could “sit for less than 2 hours in an 8 hour
workday.” (Id. at 1160.) However, the ALJ did not specifically address that

particular opinion nor provide any other explicit analysis regarding Plaintiff’s
sitting restrictions. The ALJ also did not include any sitting limitations in the RFC.
The Court agrees with Plaintiff that the ALJ erred in failing to account for
Plaintiff’s asserted inability to sit for prolonged periods.

As stated above, the ALJ determined that Plaintiff could perform sedentary
work with additional restrictions. (R. 1151.) Generally, sedentary work “requires

sitting for 6 hours and standing and/or walking for 2 hours during an 8-hour
workday.” Collins v. Astrue, 324 F. App’x 516, 517 (7th Cir. 2009) (citation omitted).
Crucially, an ALJ is required to “explain the basis for concluding that [a] Plaintiff is
able to stand, walk, and sit as required to perform sedentary work.” Bruce B. v.
Saul, No. 19 C 2639, 2021 WL 1253447, at *3 (N.D. Ill. Apr. 5, 2021). The ALJ erred
by not doing that here, particularly with respect to Plaintiff’s sitting abilities and
her testimony regarding her sitting restrictions. See Corral v. Berryhill, No. 16 C

4315, 2017 WL 3070722, at *9 (N.D. Ill. July 19, 2017) (“But ALJ Supergan did not
adequately explain why she rejected Corral’s allegation that he cannot sit or stand
for long periods of time, a limitation that was also proffered by two medical experts
and Koite.”); Fox v. Colvin, No. 14 C 4432, 2016 WL 4548999, at *8 (N.D. Ill. Sept. 1,
2016) (“In her decision, however, the ALJ did not discuss any of the evidence
regarding Plaintiff’s inability to sit, nor did she rely on any medical opinion as to
that ability, and simply concluded that – by inference – Plaintiff’s ability in this
area was unlimited. This was improper.”). The ALJ’s error in that regard requires
that this matter be remanded. See DeJohnette v. Colvin, No. 13 C 1787, 2015 WL

9315536, at *7 (N.D. Ill. Dec. 23, 2015) (“[B]ecause without an explicit discussion of
these alleged limitations [regarding sitting and standing] it is impossible to
determine whether the ALJ evaluate[d] all limitations that arise from medically
determinable impairments, even those that are not severe, remand is appropriate.”)
(citation and internal quotations omitted); Washington v. Colvin, No. 12 C 4995, 2013 WL 1903247, at *11 (N.D. Ill. May 7, 2013) (“Though the ALJ minimally

articulated why she found Washington’s alleged inability to walk and stand to be
incredible, she made no reference to Washington’s testimony regarding her inability
to sit. This lack of analysis warrants reversal.”); Hager v. Berryhill, No. 17 CV 7772, 2018 WL 4095095, at *4 (N.D. Ill. Aug. 28, 2018) (remand required where “[t]he
ALJ failed to analyze Plaintiff’s claims that he cannot sit or stand for prolonged
periods, that he cannot sit for longer than 45 minutes at a time, and that he cannot
stand for longer than five minutes at a time”).

Based on its conclusion that remand is necessary for the above reasons, the
Court need not explore in detail the remaining errors claimed by Plaintiff. The
Court emphasizes that the Commissioner should not assume these issues were
omitted from the opinion because no error was found. Indeed, the Court admonishes
the Commissioner that, on remand, special care should be taken to ensure that the
ALJ’s RFC assessment is properly supported and complete and Plaintiffs subjective
symptoms are properly evaluated.
CONCLUSION
For the foregoing reasons, Plaintiff's motion for summary remand [16] is
granted, and the Commissioner’s cross-motion for summary judgment [17] is
denied. The Court finds that this matter should be remanded to the Commissioner
for further proceedings consistent with this Order.

SO ORDERED. ENTERED:

                                    Dee?  He 22 

DATE: February 25, 2026
HON. DANIEL P. McLAUGHLIN
United States Magistrate Judge