Huckins v. Bisignano
- Jeffrey Bryan
- 0:24-cv-02262
- U.S. District Court · District of Minnesota
- 2
In Lori A-H v. Bisignano, Judge Bryan reversed the Social Security Commissioner's disability decision and sent the case back for a new administrative review due to multiple errors by the administrative law judge.
People who have applied for Social Security disability benefits and whose claims were denied by an administrative law judge — particularly those whose ALJ decisions involved conflicts with the Dictionary of Occupational Titles, improper evaluation of physical limitations, or unexplained omissions of mental limitations from residual functional capacity assessments.
What happened
In Lori A-H v. Bisignano (Case No. 24-CV-02262), a plaintiff identified only as Lori A-H challenged the Social Security Administration's denial of her disability benefits in federal court in Minnesota. A magistrate judge reviewed the case and issued a report recommending that the Commissioner's final decision be reversed and sent back for a new administrative review, identifying three specific errors made by the administrative law judge (ALJ) who originally decided the case.
The three errors identified were: (1) the ALJ failed to resolve a conflict between testimony from a vocational expert and the Dictionary of Occupational Titles regarding overhead reaching; (2) the ALJ improperly evaluated Lori A-H's ability to handle objects and operate hand controls; and (3) the ALJ did not explain why mental limitations were left out of the evaluation of her residual functional capacity — the assessment of what work she is still capable of doing despite her impairments. Neither party objected to the magistrate judge's report within the required time period.
Because no objections were filed, Judge Jeffrey M. Bryan reviewed the report only for clear error, found none, and adopted it in full. Judge Bryan reversed the Commissioner's final decision and remanded — sent the case back — to the Social Security Administration for further proceedings consistent with the magistrate judge's recommendations. The court ordered that judgment be entered accordingly.
The detailed version
- Huckins v. Bisignano · No. 0:24-cv-02262
- Jeffrey M. Bryan
- Aug. 15, 2025
Background
Plaintiff Lori A-H (identified by first name and last initial only, pursuant to this district's policy for Social Security cases) brought this action challenging a final decision of the Commissioner of Social Security denying her disability benefits. The defendant is Frank Bisignano in his capacity as Commissioner of Social Security.
The case was referred to United States Magistrate Judge John F. Docherty, who issued a Report and Recommendation (R&R) on July 23, 2025, recommending that the Commissioner's final decision be reversed and the matter remanded for further administrative proceedings.
Errors Identified by the Magistrate Judge
The R&R identified three distinct legal errors committed by the Administrative Law Judge (ALJ) — the agency official who initially adjudicated Lori A-H's disability claim:
1. Vocational Expert Conflict: The ALJ failed to resolve a conflict between testimony provided by a vocational expert (a specialist who testifies about what jobs exist in the economy) and the Dictionary of Occupational Titles — a standard reference used in disability proceedings — specifically regarding the requirement of overhead reaching.
2. Handling and Hand Controls: The ALJ erred in evaluating Lori A-H's ability to handle objects and her ability to operate hand controls.
3. Mental Limitations Omitted from RFC: The ALJ did not explain why mental limitations were excluded from Lori A-H's residual functional capacity (RFC) evaluation. RFC is the agency's assessment of the most a claimant can still do in a work setting despite her impairments, and it is a central component of the disability determination.
Procedural Posture and Standard of Review
Neither party filed objections to the R&R within the time permitted under District of Minnesota Local Rule 72.2(b)(1). When no timely objections are filed, the district court reviews the magistrate judge's R&R for clear error only, citing Federal Rule of Civil Procedure 72(b) and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996).
Ruling
Judge Bryan found no clear error in the R&R and adopted it in full. The court:
1. Adopted the R&R (Doc. No. 18). 2. Reversed the Commissioner's final decision and remanded the matter pursuant to sentence four of 42 U.S.C. § 405(g) for further administrative proceedings consistent with the magistrate judge's R&R.
The court ordered that judgment be entered accordingly. A sentence-four remand under 42 U.S.C. § 405(g) is a final judgment that sends the case back to the agency for additional proceedings; it does not award benefits directly but requires the agency to reconsider the claim in light of the identified errors.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.