A disabled child's benefits case gets a second look after flawed medical review.
Lachelle O On Behalf of Lf a Minor v. Bisignano
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A disabled child's benefits case gets a second look after flawed medical review.
Why it matters
In Lachelle O., on behalf of L.F., a minor v. Bisignano, a federal magistrate judge in the District of Maryland remanded a Social Security disability case back to the agency for further proceedings. The court found reason to question the ALJ's decision to give greater weight to a non-examining consulting doctor's opinion over the opinion of the treating nurse practitioner who had actually examined and treated the child.
Who it affects
This ruling directly affects the minor child L.F. and her mother, who have been seeking SSI disability benefits since 2017. More broadly, it is relevant to families of children with mental health impairments who are navigating Social Security disability claims and whose treating providers' opinions conflict with those of non-examining consultants.
What happens next
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Decision issued Oct 8, 2026
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Parties can ask the same court to reconsider. Then: possible appeal to the circuit court.
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- Decision issued Oct 8, 2026
- Possible rehearingParties can ask the same court to reconsider.
- Possible appeal to the circuit court
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Oct 8, 2026
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DEEPER READ
This case involved a Social Security Supplemental Security Income (SSI) claim filed on behalf of L.F., a minor child born in May 2010, by her mother Lachelle O. The central question was whether the Social Security Administration's Administrative Law Judge (ALJ) properly evaluated the medical evidence when concluding that L.F. was not disabled. L.F. had been found to have severe impairments including explosive anger disorder, bipolar disorder, and ADHD, but the ALJ determined those impairments did not meet or functionally equal the severity required for a disability finding under the SSI rules for children. The ALJ evaluated L.F. under the three-step process used for child disability claims. At the final step, the ALJ weighed how L.F. functioned across six specific areas of life, called domains. The ALJ found L.F. had less than a marked limitation in four domains and no limitation in two others. To qualify as disabled, a child must have marked limitations in at least two domains, or an extreme limitation in one. The ALJ's conclusion that L.F. did not meet this threshold led to the denial of benefits. The self-represented mother argued that the ALJ improperly favored the opinion of a consulting doctor, Dr. Maryann Kristin Price, who never examined or treated L.F., while discounting the opinion of Rachel Murray, a certified registered nurse practitioner who had actually examined and treated L.F. Dr. Price found no limitation or less-than-marked limitation in all six domains, while Murray found extreme limitations in three domains. The court found the plaintiff's concern about this weighting decision persuasive enough to warrant sending the case back to the agency for additional review. The court did not rule that L.F. is disabled. Instead, it ordered the case remanded so the agency can take another look at the evidence, particularly the competing medical opinions, using the proper legal standards. The court's role was limited to determining whether the ALJ's decision was supported by substantial evidence and whether proper legal standards were applied.
CITATION AND RECORD
Record source: CourtListener
UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND CHAMBERS OF 6500 Cherrywood Lane TIMOTHY J. SULLIVAN Greenbelt, Maryland 20770 CHIEF MAGISTRATE JUDGE Telephone: (301) 344-3593 October 8, 2026 LETTER TO ALL PARTIES: RE: Lachelle O., on behalf of L.F., a minor v. Bisignano Case No. 1:25-cv-02848-TJS Dear Parties: On August 29, 2025, Lachelle O., on behalf of her minor child, L.F. (“Plaintiff”), filed this action seeking review of the Social Security Administration’s final decision denying Plaintiff’s claim for Social Security benefits. ECF No. 1. The case has been assigned to me for all proceedings with the parties’ consent pursuant to 28 U.S.C. § 636 and Local Rule 301.1 Having considered the submissions of the parties (ECF Nos. 15, 16 & 20), I find that no hearing is necessary. See Loc. R. 105.6. This Court must uphold the decision of the agency if it is supported by substantial evidence and if the agency employed the proper legal standards. 42 U.S.C. §§ 405(g), 1383(c)(3); Mascio v. Colvin, 780 F.3d 632, 634 (4th Cir. 2015). Following its review, this Court may affirm, modify, or reverse the Commissioner, with or without a remand. See 42 U.S.C. § 405(g); Melkonyan v. Sullivan, 501 U.S. 89 (1991). Under that standard, I will construe Plaintiff’s submissions collectively as a motion for remand, grant the motion, and remand the case for further proceedings. An application for Supplemental Security Income (“SSI”) was filed on L.F.’s behalf on November 30, 2017. See ECF No. 20 at 2. The application was denied at the initial level and on reconsideration. Id. On April 23, 2020, an ALJ issued a written determination finding that L.F. was not disabled, and the Appeals Council denied Plaintiff’s request for review. Id. Plaintiff applied for SSI on L.F.’s behalf again on June 2, 2021. Id. This application was denied initially and upon reconsideration. On October 10, 2023, an ALJ determined that L.F. was disabled, but on its own motion the Appeals Council remanded the case for additional proceedings. Id. On remand, an ALJ held another hearing on June 27, 2024. Id. On February 18, 2025, the ALJ issued a written decision finding that L.F. was not disabled. Tr. 9-15. The Appeals Council denied Plaintiff’s request for review. ECF No. 20 at 3. Plaintiff filed this action to obtain review of the ALJ’s February 18, 2025 decision finding that L.F. is not disabled. Under the Social Security Act, an individual under the age of 18 will be considered disabled if that individual has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and which can be 1 This case was originally assigned to Judge Douglas R. Miller. On March 30, 2026, it was reassigned to me. expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months. 42 U.S.C. § 1382c(a)(3)(C)(i). But if the individual engages in substantial gainful activity, they will not be considered disabled. Id. § 1382c(a)(3)(C)(ii). To evaluate whether a child is disabled, an ALJ must follow a three-step sequential evaluation process. See 20 C.F.R. § 416.924. At step one, the ALJ determines whether the child is engaged in substantial gainful activity. Id. § 416.924(b). If the child is engaged in substantial gainful activity, the ALJ will find that they are not disabled. At step two, the ALJ determines whether the child has medically determinable impairments that are severe. Id. § 416.924(c). If a child does not have severe medically determinable impairments, the ALJ will find that they are not disabled. At step three, the ALJ determines whether the child’s impairments meet, medically equal, or functionally equal a listed impairment. Id. § 416.924(d). To meet the requirements of a listing, a child “must have a medically determinable impairment(s) that satisfies all of the criteria of the listing.” 20 C.F.R. § 416.925(d). A child’s impairments are medically equivalent to a listing if the medical findings regarding the impairments are at least equal in severity and duration to the criteria of any listed impairment. 20 C.F.R. § 416.926(a). For a child’s impairments to functionally equal a listing, the child must have severe impairments that result in “marked” limitations in at least two of six identified domains, or an “extreme” limitation in one domain. 20 C.F.R. § 416.926a. The six domains are: (i) Acquiring and using information; (ii) Attending and completing tasks; (iii) Interacting and relating with others; (iv) Moving about and manipulating objects; (v) Caring for yourself; and, (vi) Health and physical well-being. Id. § 416.926a(b)(1). Because L.F. was born in May 2010, the ALJ followed the three-step process for determining whether a child is disabled under the Social Security Act. Tr. 10. At step one, the ALJ determined that L.F. was not engaged in substantial gainful activity. Id. At step two, the ALJ found that L.F. has the following severe impairments: explosive anger disorder, bipolar disorder, and Attention Deficit Hyperactivity Disorder (ADHD). Id. At step three, the ALJ found that L.F. does not have impairments that meet or medically equal a listed impairment. Tr. 10-11. And the ALJ further determined that L.F. does not have impairments that functionally equal the severity of the listings. In making this determination, the ALJ considered how L.F. functions in the six domains identified in 20 C.F.R. § 416.926a(b)(1). The ALJ found that L.F. had less than a marked limitation in acquiring and using information; attending and completing tasks; interacting and relating with others; and the ability to care for herself. Tr. 11. And the ALJ found that L.F. had no limitation in moving about and manipulating objects or in health and physical well-being. Id. Plaintiff is self-represented. She filed two briefs, but they are nearly identical. ECF Nos. 15 & 16. Plaintiff’s arguments are not presented in a traditional format, but she clearly identifies her primary complaint with the ALJ’s decision: the ALJ gave “partial to great persuasive value” to the opinion of Maryann Kristin Price, Ph.D., a consulting medical source who did not examine or treat L.F., but gave only “limited persuasive value” to the opinion of Rachel Murray, CRNP, a medical source who has examined and treated L.F. See ECF No. 16 at 4-5, 9; Tr. 14. Relevant here, Dr. Price opined that L.F. had either no limitation or a less-than-marked limitation in each of the six domains. Tr. 987-89. Conversely, Rachel Murray opined that L.F. had extreme limitations in attending and completing tasks; interacting and relating with others; and health and physical well-being. Tr. 750-51. The ALJ explained her assessment of these medical opinions: As for the opinion evidence, the undersigned gives partial to great persuasive value to Dr. Price’s medical interrogatory. Dr. Price’s findin
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