Connie H. v. Bisignano
- Bullard
- 0:25-cv-02247
- U.S. District Court · District of Minnesota
- 13
In Connie H. v. Bisignano, Judge Bullard recommended denying relief and dismissing the complaint with prejudice after upholding the disability decision.
Connie H.’s request for judicial relief from the denial of Social Security disability benefits; the recommendation also concerns the Commissioner of Social Security’s administrative decision.
What happened
In Connie H. v. Bisignano, Connie H. asked the court to review the Social Security Administration’s denial of her disability benefits. She argued that the administrative law judge did not properly account for her physical impairments and that the Appeals Council mishandled additional medical records.
The recommendation states that the administrative law judge relied on medical findings, medication-related pain relief, Connie H.’s activities, and other evidence in finding that she could perform light work with limitations. It also concludes that the additional records did not justify sending the case back for further review because some were outside the relevant period, some were cumulative, and Connie H. did not show a sufficient reason for not providing them earlier.
Judge Bullard recommended denying Connie H.’s requested relief and dismissing the complaint with prejudice. The document is a magistrate judge’s report and recommendation, not a final district court order, and it says the parties may file written objections within 14 days after being served.
The detailed version
- Connie H. v. Bisignano · No. 0:25-cv-02247
- Bullard
- July 31, 2026
Background
Connie H. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final administrative decision denying her application for disability income. She alleged disability based on rheumatoid arthritis, seronegative inflammatory arthritis, osteoarthritis affecting both hands and wrists, major depressive disorder, generalized anxiety disorder, and post-traumatic stress disorder.
The administrative law judge found that Connie H.’s impairments were severe but that she retained the capacity to perform light work with limitations. The judge found that she was not engaged in substantial gainful activity despite working part time and that jobs matching her capacity existed in the national economy. The administrative law judge therefore denied her application.
Issues Presented
Connie H. challenged the decision on two grounds. First, she argued that the administrative law judge did not adequately account for her limited hand use when determining her residual functional capacity, meaning her ability to perform work activities on a sustained basis despite her impairments. Second, she argued that the Appeals Council improperly failed to consider additional medical records.
Residual Functional Capacity
Judge Bullard concluded that substantial evidence supported the administrative law judge’s finding that Connie H. could frequently, but not constantly, use both hands. The evidence included Connie H.’s reports that she could lift about 20 pounds; reports of significant pain relief from medication; examinations showing normal upper-extremity strength, full grip strength, intact fine-motor dexterity, normal range of motion, no swelling, and normal sensation; a medical expert’s opinion that she could frequently handle and finger; and daily activities involving her hands and fingers.
The recommendation also states that the administrative law judge could decline to fully credit Connie H.’s subjective reports of pain because they were inconsistent with objective medical findings and activities such as working at a deli, preparing meals, performing household chores, knitting, painting, playing volleyball, riding a bicycle, and completing puzzles. Because the reviewing court may not reweigh evidence when substantial evidence supports the administrative law judge’s determination, Judge Bullard recommended affirming that decision without a rehearing.
Additional Medical Records
Connie H. submitted records from Essentia Health to the Appeals Council. The records included treatment notes from November 2023 through April 2024 and a July 5, 2024 record concerning a knee injury. The administrative law judge issued the decision on June 28, 2024.
The recommendation concludes that the Appeals Council properly determined that it could not consider the July 5 record because it concerned an injury outside the relevant period. Judge Bullard further concluded that the earlier records would not have changed the outcome because the full record, including those records, showed that Connie H.’s joint pain improved with medication and that she could perform activities consistent with light work.
Judge Bullard also recommended refusing a remand for consideration of the additional evidence. The recommendation states that Connie H. did not show good cause for failing to provide the records to the administrative law judge earlier, because she knew about treatment during the relevant period but did not request the records until nearly a month after the decision. It further states that the pre-June 28 records were cumulative of evidence already in the record and that the July 5 record was not material to the claimed disability period.
Recommendation and Procedure
Judge Bullard recommended that Connie H.’s requested relief be DENIED and that the Complaint be DISMISSED with prejudice. The report explains that it is not a final district court order or judgment and is not directly appealable to the Court of Appeals. It states that a party may file specific written objections within 14 days after being served with the report and recommendation.
Read the full 13-page opinion on CourtListener, the free public archive maintained by the Free Law Project.