Yoho v. Bisignano
- Nancy Brasel
- 0:24-cv-03788
- U.S. District Court · District of Minnesota
- 14
In Elija Y. v. Bisignano, Magistrate Judge Foster recommends denying the plaintiff's Social Security disability appeal because substantial evidence supports the ALJ's decision that he is not disabled.
People who have applied for Supplemental Security Income (SSI) and been denied, particularly those with autism spectrum disorder or other mental health impairments, and who are challenging an ALJ's assessment of their ability to work despite limitations.
What happened
In Elija Y. v. Bisignano (No. 24-cv-3788), a young man applied for Supplemental Security Income (SSI), a federal disability benefit program, claiming he was disabled due to autism, attention-deficit/hyperactivity disorder, obsessive-compulsive disorder, depression, eating disorder, insomnia, and problems with his feet and hands. An Administrative Law Judge (ALJ) — a government official who hears Social Security cases — went through the required five-step evaluation and determined that, while the plaintiff has several severe impairments, he retains the ability to perform certain medium-level, unskilled jobs that exist in significant numbers in the national economy, and therefore is not disabled.
The plaintiff asked the federal court to reverse or send the case back for further review, arguing that the ALJ's assessment of what he can still do despite his limitations (called a residual functional capacity, or RFC) did not properly account for his inability to function independently, his need for supported environments in school, and the risk that his mental impairments would cause him to be off-task at work. The Commissioner of Social Security defended the ALJ's decision, pointing to supporting evidence in the record, including medical opinions from consulting psychologists and an examining doctor, as well as the plaintiff's own reported activities such as traveling to Singapore alone and interacting with medical staff.
Magistrate Judge Dulce J. Foster recommends that the plaintiff's request for relief be denied, the Commissioner's request for relief be granted, and the case be dismissed with prejudice. The recommendation concludes that the ALJ properly weighed the evidence — including medical opinions, the plaintiff's self-reports, and his academic records — and that the record as a whole provides substantial evidence supporting the ALJ's finding that the plaintiff is not disabled. This is a recommendation, not a final order; the parties have 14 days to file written objections with the district court.
The detailed version
- Yoho v. Bisignano · No. 0:24-cv-03788
- Nancy Brasel
- Aug. 8, 2025
Background
Plaintiff Elija Y. applied for Supplemental Security Income (SSI) under Title XVI of the Social Security Act on January 6, 2022. At the time of application, he was 19 years old with a high school education and prior work experience in the produce department of a retail store. He alleged a disability onset date of March 15, 2020, stemming from autism, attention-deficit/hyperactivity disorder (ADHD), obsessive-compulsive disorder (OCD), eating disorder, depression, insomnia, and problems with both feet and hands.
Administrative Proceedings
The Social Security Administration denied Plaintiff's application initially and on reconsideration. An Administrative Law Judge (ALJ) held a hearing on January 19, 2024, at which Plaintiff — represented by counsel — and a vocational expert (a professional who testifies about available jobs) testified.
The ALJ conducted the standard five-step sequential evaluation:
- Step 1: The ALJ found Plaintiff had not engaged in substantial gainful activity since his alleged onset date. - Step 2: The ALJ found Plaintiff has multiple severe impairments: autism spectrum disorder, depression, anxiety, bipolar disorder, panic disorder, OCD, ADHD, osteoarthritis, and pronation deformity of both feet. The ALJ found cannabis and alcohol use disorder non-severe and found no medically determinable wrist impairment. - Step 3: The ALJ found Plaintiff's impairments do not meet or medically equal any impairment in the Listing of Impairments (a catalog of presumptively disabling conditions), because Plaintiff has only moderate — not extreme or two marked — limitations across the four broad areas of mental functioning. - Step 4 (RFC determination): The ALJ found Plaintiff retains the residual functional capacity (RFC) — the most he can do despite his limitations — to perform medium work, with restrictions including: avoiding unprotected heights and moving mechanical parts; only frequent operation of foot controls; understanding, remembering, and carrying out only simple instructions; only occasional interaction with supervisors and coworkers; no interaction with the public; no work requiring specific production rates (e.g., assembly line or hourly quotas); and only occasional adaptation to changes in a routine work setting. The ALJ found Plaintiff cannot perform his past relevant work as a stock clerk because it exceeds this RFC. - Step 5: Relying on vocational expert testimony, the ALJ found Plaintiff can perform other jobs existing in significant numbers in the national economy, including cleaner II (approximately 53,010 jobs), kitchen helper (approximately 120,293 jobs), and hand packager (approximately 70,335 jobs). The ALJ concluded Plaintiff is not disabled.
The Appeals Council denied Plaintiff's request for review, making the ALJ's decision the Commissioner's final decision. This lawsuit followed.
Issues Presented
Plaintiff argued that (1) the ALJ's RFC determination failed to account for his inability to function independently, and (2) the RFC is not supported by substantial evidence. He specifically argued the ALJ overlooked his need for supported environments (e.g., special education services, an individualized education plan) and did not account for potential off-task behaviors caused by his mental impairments.
Legal Standard
Judicial review of the Commissioner's decision is limited to determining whether the decision is supported by substantial evidence — meaning more than a scintilla, but 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). The court does not reweigh evidence; if two inconsistent positions could be drawn from the record and one reflects the ALJ's findings, the court must affirm.
Analysis
RFC and Medical Opinion Evidence
Magistrate Judge Foster found the ALJ's RFC determination well-supported. The ALJ permissibly relied on prior administrative findings from State agency psychological consultants Drs. Demetri Dress (Psy.D.) and Ray Conroe (Ph.D., L.P.), both of whom found no more than moderate functional limitations. The ALJ also found persuasive the September 2022 opinion of examining physician Dr. Alford Karayusuf, who concluded Plaintiff could follow simple instructions, maintain pace and persistence on simple routine tasks within a restricted social environment, and manage benefits — though the ALJ imposed greater restrictions than Dr. Karayusuf recommended, barring all public contact.
Under regulations revised in 2017, ALJs are no longer required to give controlling or special deference to treating physicians; they evaluate all medical opinions for supportability and consistency.
Plaintiff's Subjective Reports and Daily Activities
The ALJ acknowledged Plaintiff's self-reported difficulties — including trouble with instructions, social isolation, and reliance on professional support in school — but found them inconsistent with other record evidence showing: a full-scale IQ of 104; ability to travel to Singapore alone; intact memory, judgment, and cognition at medical appointments; appropriate grooming; normal mood and affect; no prior job termination for interpersonal problems; and school records noting Plaintiff's independence as a strength and his own suggestion that special education services "may not be necessary." The ALJ also noted Plaintiff's lack of any mental health treatment or medication management during the relevant period, in part because Plaintiff reported he did not find medication effective. Under 20 C.F.R. § 416.930(b), an ALJ may discount alleged symptom severity when a claimant does not follow prescribed treatment.
Plaintiff's Academic Records Argument
The court found the ALJ did consider Plaintiff's academic records, including records suggesting autism could impede workplace functioning. However, those same records also reflected positive indicators. The court noted Plaintiff offered no professional medical evaluation to support his contention that he cannot function independently in a workplace.
Reweighing Argument
The court emphasized that its role is not to reweigh evidence, but to determine whether substantial evidence supports the ALJ's decision — a threshold the court found satisfied here.
Recommendation
Magistrate Judge Foster recommends:
- Plaintiff's Request for Relief (ECF No. 9) be denied.
- Defendant's Request for Relief (ECF No. 11) be granted.
- This matter be dismissed with prejudice.
This is a Report and Recommendation from a magistrate judge, not a final order. Under Local Rule 72.2(b)(1), any party may file written objections within 14 days of service.
Read the full 14-page opinion on CourtListener, the free public archive maintained by the Free Law Project.