{"id":449,"date":"2026-01-08T12:00:00","date_gmt":"2026-01-08T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=449"},"modified":"2026-01-08T12:00:00","modified_gmt":"2026-01-08T12:00:00","slug":"chasity-bisignano-social-security-disability-reversal-remand","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=449","title":{"rendered":"Chasity T. v. Bisignano \u2014 N.D. Cal. reverses and remands SSA disability denial for further proceedings"},"content":{"rendered":"
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Case<\/dt>\n
Chasity T. v. Frank Bisignano<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Northern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-08<\/dd>\n
Docket No.<\/dt>\n
3:25-cv-02628<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Social Security disability; 42 U.S.C. \u00a7 405(g); five-step sequential evaluation; Listing 11.02; substantial evidence review; reversal and remand; Bray v. Commissioner<\/em>; Stout v. Commissioner<\/em><\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Plaintiff Chasity T. applied for disabled adult child insurance benefits and supplemental security income on April 7, 2022, alleging a disability onset date of September 3, 2014. Their claims were denied initially, on reconsideration, and after a March 29, 2024 ALJ hearing, where the ALJ found Chasity not disabled at any point from the alleged onset date through the date of decision. The ALJ identified mild neurocognitive disorder, depressive disorder, generalized anxiety disorder, post-traumatic stress disorder, migraines, and obesity as severe impairments, but concluded at step three that none of the impairments alone or in combination met or equaled a listed impairment. The ALJ also assessed a residual functional capacity for light work with various postural, environmental, and mental limitations. At step five, the ALJ relied on a vocational expert to conclude Chasity could perform jobs available in the national economy.<\/p>\n

The Appeals Council denied review, making the ALJ\u2019s decision final. Chasity sought judicial review under 42 U.S.C. \u00a7 405(g) in the Northern District of California, asserting that the ALJ made legal errors and that the decision was not supported by substantial evidence.<\/p>\n

The Court’s Holding<\/h2>\n

Judge Rita F. Lin reversed and remanded the Commissioner\u2019s decision for further administrative proceedings.<\/p>\n

Reviewing under the substantial-evidence standard articulated in Stout v. Commissioner<\/em> and Burch v. Barnhart<\/em>, the court found multiple significant errors in the ALJ\u2019s analysis that required remand. The court emphasized that under Bray v. Commissioner<\/em>, review is limited to the reasoning and factual findings actually offered by the ALJ \u2014 courts cannot affirm based on post-hoc rationalizations.<\/p>\n

The court found that the ALJ\u2019s step three analysis of Listing 11.02 (epilepsy as a potential equivalency for headaches) was not supported by the record. Although the ALJ stated there was no evidence of headaches at the required frequency despite adherence to prescribed treatment, the court identified evidence in the record that contradicted that conclusion. The ALJ also failed adequately to consider the cumulative effect of Chasity\u2019s multiple severe and non-severe impairments \u2014 including idiopathic thrombocytopenia and history of stroke \u2014 at step three.<\/p>\n

The court further found errors in the ALJ\u2019s residual functional capacity assessment, including failure to credit medical opinion evidence and an inadequate explanation of how the limitations adopted in the RFC accounted for Chasity\u2019s mental impairments and migraine frequency. The vocational expert testimony at step five rested on a flawed RFC and could not support the ultimate disability determination.<\/p>\n

The court reversed the final decision and remanded for further administrative proceedings consistent with the order.<\/p>\n

Key Takeaways<\/h2>\n