Cramblitt v. Bisignano
- David Schultz
- 0:25-cv-00746
- U.S. District Court · District of Minnesota
- 5
In Charles A. C. v. Bisignano, Judge Blackwell upheld the Social Security Administration's denial of disability benefits, finding the administrative law judge adequately explained limiting the plaintiff to 'superficial' rather than 'brief and superficial' interactions.
People who applied for Social Security disability benefits and were denied, particularly those whose cases involve an ALJ's residual functional capacity finding that does not adopt all specific language used by agency medical consultants. This ruling signals that an ALJ can decline to use terms like 'brief' if adequately explained, even when agency psychologists recommended such a limitation.
What happened
In Charles A. C. v. Bisignano (Civ. No. 25-746), a Minnesota federal court reviewed a Social Security Administration decision denying the plaintiff's application for disability benefits. The plaintiff sought to reverse or send the case back to the agency, arguing that the administrative law judge (ALJ) failed to explain why the plaintiff's work-related interactions were limited to 'superficial' contacts rather than 'brief and superficial' contacts, as two agency psychologists had recommended.
The court focused on whether the ALJ built a sufficient 'logical bridge' between the evidence and his conclusions. The ALJ had explained that the word 'brief' is not a vocationally defined term and instead described the plaintiff's allowed interactions with specific examples — such as taking instructions, relaying information, and transferring material. The court found that those examples are consistent with the idea that interactions would also likely be brief, and that the agency psychologists never explained 'brief and superficial' in a way that clearly conflicted with the ALJ's findings. The court also noted that the ALJ discussed other evidence of the plaintiff's mental limitations, including more recent evidence that post-dated the psychologists' opinions.
Judge Jerry W. Blackwell overruled the plaintiff's objection to the Magistrate Judge's earlier Report and Recommendation, accepted that Report and Recommendation, denied the plaintiff's request to reverse or remand the Commissioner's decision, granted the defendant's request to affirm, and affirmed the Commissioner's decision.
The detailed version
- Cramblitt v. Bisignano · No. 0:25-cv-00746
- David Schultz
- Oct. 7, 2025
Background
The plaintiff, identified in court records only as Charles A. C., applied for Social Security disability benefits and was denied at the administrative level by an administrative law judge (ALJ) — an agency official who conducts formal hearings and issues binding decisions on benefit claims. The plaintiff then filed suit in federal district court seeking judicial review of that denial.
Magistrate Judge's Report and Recommendation
On August 6, 2025, United States Magistrate Judge David T. Schultz issued a Report and Recommendation (R&R) recommending that the plaintiff's request to reverse or remand the Commissioner's decision be denied and that the defendant's request to affirm be granted. The plaintiff timely filed objections to the R&R.
Standard of Review
Under 28 U.S.C. § 636(b)(1), a district court reviews de novo — meaning independently and without deference — any portion of an R&R to which a party timely objects. Portions not specifically objected to are reviewed only for clear error. The underlying ALJ decision is reviewed to determine whether it is supported by substantial evidence in the record as a whole and whether it follows applicable legal standards.
The Plaintiff's Objection
The plaintiff's central objection was that the R&R improperly supplied a rationale for the ALJ. Specifically, two agency psychologists had opined that the plaintiff should be limited to "brief and superficial" interactions with others. The ALJ's residual functional capacity (RFC) finding — the assessment of the most a claimant can still do despite limitations — restricted the plaintiff to "superficial" interactions only, without explicitly including a "brief" duration limit. The plaintiff argued the ALJ gave no reason for omitting the word "brief."
Court's Analysis
The ALJ's Explanation Was Sufficient
Judge Blackwell found that the ALJ had, in fact, directly explained the omission of "brief": the ALJ stated he declined to use the term because it is not vocationally defined, and instead opted for "more specific, vocationally defined, and policy compliant language." Rather than limiting the plaintiff to "superficial contact" in a general sense, the ALJ described specific types of permissible interactions — taking instructions, relaying information, and transferring material.
No Meaningful Conflict with Agency Psychologists' Opinions
The court agreed with the R&R's citation to prior caselaw recognizing that the types of interactions the ALJ described would also likely be brief in practice. The court acknowledged the plaintiff's argument that the example interactions do not inherently imply a brief time frame, but found that they do not necessarily imply an extended time frame either. Critically, the agency psychologists did not explain what they meant by "brief and superficial" in a way that was clearly at odds with the ALJ's RFC finding. The court concluded the plaintiff's parsing of terminology did not establish a genuine conflict warranting remand.
Broader Evidentiary Support
The court further noted that the ALJ assessed the agency psychologists' opinions and reviewed other evidence of the plaintiff's mental limitations and ability to interact with others — including evidence of longer-duration interactions and evidence that post-dated the psychologists' opinions. Nothing in the record indicated the ALJ had forgotten or ignored the psychologists' opinions. The court found that the ALJ's ruling could be logically followed and that the RFC finding was supported by record evidence.
Disposition
Judge Blackwell:
- Overruled the plaintiff's objection (Doc. No. 19);
- Accepted the Report and Recommendation (Doc. No. 17);
- Denied the plaintiff's request to reverse or remand the Commissioner's decision (Doc. No. 14);
- Granted the defendant's request to affirm the Commissioner's decision (Doc. No. 16); and
- Affirmed the Commissioner's decision.
The court directed that judgment be entered accordingly.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.