Meyer v. Bisignano
- Donovan Frank
- 0:25-cv-03473
- U.S. District Court · District of Minnesota
- 7
In Annette M. v. Bisignano, Judge Frank upheld the Social Security Administration's denial of disability benefits, finding the ALJ's decision was supported by substantial evidence.
People who have applied for Social Security disability benefits and had their applications denied, particularly those whose cases involved questions about whether the agency was required to order an independent medical examination or adequately considered their reported symptoms.
What happened
In Annette M. v. Frank Bisignano, Commissioner of Social Security, No. 25-3473, a woman named Annette M. asked a federal court to send her disability benefits case back to the Social Security Administration for a new review. An Administrative Law Judge (ALJ) had denied her applications for disability insurance benefits and supplemental security income, and she argued the ALJ made two key errors in assessing how much she was still able to work despite her medical conditions — which included migraines, headaches, and cervical spine problems.
Annette M. raised two main arguments. First, she said the ALJ should have ordered an independent medical examination instead of reviewing raw medical records on her own. Second, she said the ALJ wrongly dismissed her descriptions of her own symptoms and pain. She also argued the ALJ had improperly formed a conclusion about her work capacity before fully weighing the evidence, and then rejected her complaints simply because they did not match that predetermined conclusion.
Judge Donovan W. Frank of the United States District Court for the District of Minnesota denied Annette M.'s request and affirmed the Commissioner's denial of benefits. The court found that the ALJ's assessment of her work capacity was supported by substantial evidence in the record, that an independent medical examination was not necessary under the circumstances, and that the ALJ adequately considered Annette M.'s reported symptoms — including medication effects and daily activities — beyond just objective medical data. The complaint was dismissed with prejudice.
The detailed version
- Meyer v. Bisignano · No. 0:25-cv-03473
- Donovan Frank
- Sept. 1, 2026
Background
Annette M. applied for Social Security disability insurance benefits and supplemental security income in January 2023, initially alleging a disability onset date of November 9, 2018, later amended to August 30, 2023. An ALJ (Administrative Law Judge — the Social Security Administration official who conducts hearings and issues initial decisions) denied her applications on July 9, 2024, and that decision became final on July 9, 2025.
The ALJ followed the standard five-step sequential evaluation process used in Social Security disability determinations. At step two, the ALJ identified Annette M.'s severe impairments as migraines, headaches, cervical facet joint arthropathy, and cervical spine degenerative disc disease. At step three, the ALJ found these impairments did not meet or equal any listed impairment in the Social Security Administration's Listing of Impairments. The ALJ then assessed Annette M.'s Residual Functional Capacity (RFC) — the most a claimant can do in a work setting despite her limitations. Because Annette M. had no past relevant work, the ALJ proceeded to step five and found that jobs she could perform existed in significant numbers in the national economy, resulting in a finding of not disabled.
Significantly, the ALJ did not order a consultative examination (an independent medical evaluation arranged by the agency). The only medical opinion from after the amended alleged onset date came from a state agency medical consultant at the reconsideration level, whose opinion was rendered on September 26, 2023.
Legal Standard
A federal court reviewing a Social Security disability denial affirms if the ALJ's decision is supported by substantial evidence in the record as a whole 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 to support a conclusion. Where substantial evidence supports two conflicting outcomes, the ALJ operates within a "zone of choice" and the court will not overturn the decision even if it might have reached a different conclusion.
Issue 1: Consultative Examination
Annette M. argued the ALJ was required to order a consultative examination to evaluate her functioning after her amended onset date, given the worsening of her migraines.
The court explained that while an ALJ has a duty to develop the record — which can include arranging a consultative examination — this duty is not unlimited. Failure to order such an examination is reversible error only when the examination was necessary for an informed decision. A consultative examination is not required where the ALJ's ultimate determination is supported by substantial evidence.
The court found no error here. The worsening of Annette M.'s migraines began in March 2023, meaning the state agency medical consultant on reconsideration did review those records. The court found that after the consultant's September 2023 opinion, the record showed changes to Annette M.'s treatment plan but not to her symptoms. The court noted Annette M. did not explain why the ALJ was unequipped to analyze the remaining records herself, and therefore found the record was adequately developed.
Issue 2: Subjective Complaints
Annette M. argued the ALJ improperly discounted her subjective descriptions of her symptoms.
Under Social Security Ruling 16-3p, an ALJ must first determine whether a medically determinable impairment could reasonably produce the claimant's symptoms, then evaluate the intensity and persistence of those symptoms. An ALJ may discount subjective complaints where there are inconsistencies in the record as a whole, but cannot rely solely on objective medical evidence. The ALJ must also consider the so-called Polaski factors: (i) daily activities; (ii) duration, frequency, and intensity of pain; (iii) precipitating and aggravating factors; (iv) dosage, effectiveness, and side effects of medication; and (v) functional restrictions.
The court found the ALJ did not rely solely on objective medical evidence. The ALJ extensively discussed the effectiveness and side effects of Annette M.'s medications and addressed her daily activities elsewhere in the decision. The court acknowledged it might weigh the evidence differently but stated it cannot reweigh the evidence on review.
Annette M. also argued the ALJ predetermined her RFC and then rejected her subjective complaints because they were inconsistent with that predetermined RFC — a recognized legal error. The court acknowledged the ALJ used language referring to evidence being "consistent with the limitations set forth in the residual functional capacity," but found that reading the decision as a whole, the ALJ primarily evaluated whether Annette M.'s subjective complaints were inconsistent with other evidence in the record, not with a predetermined RFC conclusion. The court therefore rejected this argument.
Disposition
Judge Frank denied Annette M.'s request for relief, granted the Commissioner's request for relief, and dismissed the complaint with prejudice.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.