Keith H. v. Bisignano
- Donovan Frank
- 0:25-cv-02132
- U.S. District Court · District of Minnesota
- 6
In Keith H. v. Bisignano, Judge Frank dismissed with prejudice a challenge to Social Security's denial of disability benefits, finding the ALJ's decision was supported by substantial evidence.
Individuals who have been denied Social Security supplemental security income benefits and are seeking federal court review, particularly those whose claims involve mental-health impairments and disputed findings about limitations in social interaction.
What happened
In Keith H. v. Bisignano (Civil No. 25-2132), a Minnesota federal court reviewed a Social Security Administration decision denying supplemental security income to Keith H., who applied for benefits in April 2021. An Administrative Law Judge (ALJ) — a government official who conducts hearings and decides disability claims — found that Keith H. had three severe mental-health impairments (schizoaffective disorder, anxiety disorder, and substance use disorder) but that he could still perform certain routine jobs and was therefore not disabled.
Keith H. argued that the ALJ wrongly concluded he had only moderate limitations in interacting with others, contending that nearly every provider in his file supported a finding of more serious ("marked") limitations. He challenged the ALJ's reliance on the opinion of a psychological consultative examiner, Dr. Dustin Warner, arguing that Dr. Warner did not fully explain his finding of only moderate limitations in social interaction.
Judge Donovan W. Frank denied Keith H.'s request for relief, granted the Commissioner's request to affirm, and dismissed the case with prejudice. The court found that the ALJ properly reviewed all relevant evidence — including medical records, provider observations, and Keith H.'s own testimony — and that substantial evidence (meaning enough evidence that a reasonable mind could accept it) supported the ALJ's conclusion. The court noted that Keith H.'s providers generally found him stable when taking medication, that two other consultants also found only moderate limitations, and that the court is not permitted to reweigh the evidence on its own.
The detailed version
- Keith H. v. Bisignano · No. 0:25-cv-02132
- Donovan Frank
- June 25, 2026
Background
Keith H. applied for supplemental security income (SSI) — a federal benefit program for low-income individuals with disabilities — in April 2021. After two hearings, an Administrative Law Judge (ALJ) denied the application on April 10, 2024. That decision became final on March 28, 2025, after which Keith H. filed suit in federal district court seeking judicial review.
The ALJ's Five-Step Analysis
The ALJ followed the standard five-step sequential evaluation process under 20 C.F.R. § 416.920(a)(4). At step two, the ALJ found three severe impairments: schizoaffective disorder, anxiety disorder, and substance use disorder. At step three, the ALJ found those impairments did not meet or equal any listing in the Listing of Impairments (a regulatory catalog of conditions severe enough to qualify automatically for benefits).
The ALJ then assessed Keith H.'s residual functional capacity (RFC) — the most a claimant can still do despite his impairments. The ALJ found Keith H. capable of a full range of work at all exertional levels, with nonexertional (non-physical) limitations: he could understand, carry out, and persist in routine repetitive tasks; engage in only superficial interactions with supervisors and co-workers; perform no customer or client service duties; and adapt to stressors in a routine repetitive work setting. At step four, the ALJ found Keith H. could not return to his past relevant work. At step five, the ALJ found that jobs exist in significant numbers in the national economy that he could perform. The ALJ concluded Keith H. was not disabled.
Plaintiff's Challenge
Keith H. argued that the ALJ's RFC determination was not supported by substantial evidence, specifically the finding of only moderate (rather than marked) limitations in social interaction. He contended that virtually every provider in the record supported a finding of marked limitations, with the lone exception being Dr. Dustin Warner, a psychological consultative examiner whose opinion the ALJ found generally persuasive. Keith H. argued the ALJ improperly relied on Dr. Warner because Dr. Warner did not fully explain his finding of only moderate limitations.
Legal Standard
A federal court reviewing an ALJ's benefits decision will affirm if the decision is supported by substantial evidence and the ALJ made no legal error. 42 U.S.C. § 405(g). Substantial evidence is defined as less than a preponderance but enough that a reasonable mind might accept it as adequate. Where substantial evidence supports two conflicting outcomes, the ALJ operates within a "zone of choice" — the court will not overturn the decision even if it might have reached a different conclusion.
Court's Analysis
The court found that the ALJ's decision was supported by substantial evidence. The ALJ reviewed Plaintiff's testimony, medical records, and three consultant opinions. He found Plaintiff's statements about the severity of his difficulties interacting with others were not entirely consistent with the objective medical evidence, noting that providers generally found him stable, particularly when taking his medication.
The ALJ found Dr. Warner's statement generally persuasive based on his expertise, programmatic knowledge, and direct examination of Keith H. Critically, the court noted that Dr. Warner was not the only provider to identify only moderate limitations — two state psychological consultants reached the same conclusion, though the ALJ found their statements only somewhat persuasive because, unlike Dr. Warner, they did not directly examine Keith H.
The court acknowledged that while Dr. Warner did not directly explain his finding of moderate limitations, he did provide a telerecorded message describing his examination and his conclusion was otherwise supported by the medical records. The court also noted, as Keith H. himself acknowledged, that the medical documentation of his impairments was "generally sparse."
Because the burden is on the claimant to establish his RFC, and because the RFC must be supported by some medical evidence, and because the court may not reweigh the evidence, the court affirmed the Commissioner's final decision.
Disposition
The court denied Keith H.'s request for relief, granted the Commissioner's request for relief, and dismissed the complaint with prejudice.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.