Ray-Taylor v. Bisignano
- Jeffrey Bryan
- 0:24-cv-01371
- U.S. District Court · District of Minnesota
- 8
In Ray-Taylor v. Bisignano, Judge Bryan upheld the Social Security Administration's denial of disability benefits for a minor child, finding the ALJ properly weighed a treating doctor's opinion.
Families of minor children who have been denied Social Security Supplemental Security Income (SSI) disability benefits and are challenging those denials in federal court, particularly where the dispute involves how the ALJ weighed the opinion of a treating medical provider against other evidence in the record.
What happened
In Ray-Taylor v. Bisignano (Case No. 24-CV-01371), Rose R-T filed a lawsuit on behalf of her minor child, J.A.G., challenging the Social Security Administration's decision to deny J.A.G.'s application for Supplemental Security Income (SSI). J.A.G. had been diagnosed with autism spectrum disorder, generalized anxiety disorder, attention deficit hyperactivity disorder, oppositional defiance disorder, and borderline intellectual functioning disorder, among other conditions. The core dispute was whether the Administrative Law Judge (ALJ) — the official who heard the case at the agency level — properly evaluated the opinion of J.A.G.'s treating neuropsychologist, Dr. Jonathan Miller, Ph.D., who believed J.A.G. had more severe limitations than the ALJ found.
The ALJ had concluded that J.A.G. did not qualify as disabled under the applicable federal rules because J.A.G. did not have an extreme limitation in any single area of functioning, or marked limitations in two or more areas. The ALJ found only one marked limitation — in attending and completing tasks — and rated the other five functional areas as having less than a marked limitation or no limitation at all. The ALJ discounted Dr. Miller's more severe findings, explaining that Miller's opinion was not well-supported by his own examination results and was inconsistent with other medical evidence in the record, including the opinions of four other psychological and pediatric consultants. A Magistrate Judge reviewed the case and recommended affirming the ALJ's decision, and the plaintiff objected, arguing the Magistrate Judge misapplied the legal standard for weighing a treating doctor's opinion.
Judge Jeffrey M. Bryan overruled the plaintiff's objection and adopted the Magistrate Judge's recommendation, dismissing the case with prejudice. Judge Bryan found that the ALJ had clearly addressed both the 'supportability' and 'consistency' factors required by federal regulations when evaluating medical opinions, and that substantial evidence supported the ALJ's conclusions. Because the court's role is limited to determining whether substantial evidence supports the ALJ's decision — not to reweigh the evidence itself — Judge Bryan found no basis to reverse the agency's denial of benefits.
The detailed version
- Ray-Taylor v. Bisignano · No. 0:24-cv-01371
- Jeffrey M. Bryan
- Aug. 18, 2025
Background
Plaintiff Rose R-T brought this action on behalf of her minor child, J.A.G., appealing the Commissioner of Social Security's denial of J.A.G.'s application for Supplemental Security Income (SSI) under the Social Security Act. J.A.G. was diagnosed with multiple conditions, including autism spectrum disorder, generalized anxiety disorder, attention deficit hyperactivity disorder (ADHD), oppositional defiance disorder, and borderline intellectual functioning disorder/specific learning disorders.
The Administrative Decision
An Administrative Law Judge (ALJ) applied the three-step sequential evaluation framework set out in 20 C.F.R. § 416.924(a) for determining whether a minor claimant is disabled. At the third step, the ALJ assessed whether J.A.G.'s impairments functionally equaled a listed impairment by examining six domains of functioning under 20 C.F.R. § 416.926a(b)(1): (1) acquiring and using information; (2) attending and completing tasks; (3) interacting with others; (4) moving about and manipulating objects; (5) caring for oneself; and (6) health and physical well-being. A finding of disability at this step requires either an extreme limitation in one domain or marked limitations in two domains. The ALJ found only one marked limitation — in attending and completing tasks — and rated all other domains as less than marked or no limitation, thereby denying benefits.
The Dispute Over Dr. Miller's Opinion
The central issue on appeal was the ALJ's treatment of the opinion of Jonathan Miller, Ph.D., L.P., J.A.G.'s treating neuropsychologist. Dr. Miller opined that J.A.G. had an extreme limitation in interacting and relating with others, and marked limitations in moving about and manipulating objects and in caring for himself. If credited, these findings would have supported a disability determination.
The ALJ found Dr. Miller's opinions unpersuasive on multiple grounds: (1) the opinions were not supported by Dr. Miller's own examination findings — notably, that J.A.G. was pleasant and cooperative during testing, undermining an extreme limitation in social interaction; (2) the evaluation provided no significant support for a marked limitation in moving about and manipulating objects, noting only a 2018 concussion with no residual deficits; (3) Dr. Miller appeared to rely heavily on subjective reports from J.A.G.'s mother, which were not fully supported by the overall record; and (4) the opinions were inconsistent with other evidence in the record, including J.A.G.'s participation in team sports and track, his ability to manage personal care with reminders, prepare simple meals, and supervise his younger brother. Four other psychological and pediatric consultants reached different conclusions, finding only a marked limitation in attending and completing tasks and less than marked limitations in most other domains.
Legal Standard
Under 42 U.S.C. § 405(g), judicial review of an ALJ's decision is limited to whether the decision is supported by substantial evidence — a standard that is less than a preponderance of the evidence, but enough that a reasonable mind could find it adequate to support the conclusion. Cox v. Barnhart, 471 F.3d 902, 906 (8th Cir. 2006). A reviewing court may not reweigh evidence or substitute its own judgment for the ALJ's. Nash v. Comm'r, Soc. Sec. Admin., 907 F.3d 1086, 1090 (8th Cir. 2018). When considering medical opinions, the ALJ must address both 'supportability' (whether the opinion is backed by objective medical evidence) and 'consistency' (whether the opinion aligns with other medical and non-medical sources in the record) as the two most important factors. 20 C.F.R. §§ 404.1520c(c)(1)–(2). The ALJ need not use those specific words, but it must be clear that those factors were addressed. Diane M.W., No. 20-CV-2651, 2022 WL 4377731, at *5 (D. Minn. Sept. 22, 2022). Brevity in this analysis is not reversible error. Grindley v. Kijakazi, 9 F.4th 622, 631 (8th Cir. 2021).
Plaintiff's Objection
Plaintiff objected to the Magistrate Judge's Report and Recommendation (R&R), arguing that the Magistrate Judge misapplied the standard for evaluating treating physician opinions — specifically, that the Magistrate Judge failed to treat supportability and consistency as two distinct factors. Plaintiff also argued the ALJ's conclusions were 'grossly inconsistent with the record' and ignored 'overwhelming' objective evidence supporting Dr. Miller's opinion.
The Court's Ruling
Judge Bryan conducted a de novo (fresh, independent) review of the R&R and overruled the plaintiff's objections. The Court found that the ALJ's written evaluation of Dr. Miller's opinion clearly addressed both supportability and consistency — explaining why the opinion was not supported by Dr. Miller's own examination findings and why it was inconsistent with other record evidence, including the opinions of the four other consultants. The Court rejected plaintiff's argument that the ALJ improperly discounted Dr. Miller's opinion solely because it relied on the mother's subjective reports, noting the ALJ gave multiple independent reasons for finding the opinion unpersuasive. Because substantial evidence supported the ALJ's determination, the Court declined to reverse, even if a different weighing of the evidence might have been possible.
Disposition
The Court overruled Plaintiff's objections (Doc. No. 27), adopted the Magistrate Judge's R&R (Doc. No. 26), and dismissed the case with prejudice.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.