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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
SANDI DENISE WHITE,
Plaintiff,
v.
FRANK BISIGNANO, 1
Commissioner of Social Security,
Defendant.
: 	NO. 3:24-CV-00562
:
:
:
: 	(CAMONI, M.J.)
:
:
:
MEMORANDUM OPINION
This is an action brought under 42 U.S.C. § 1383(c)(3), seeking
judicial review of the final decision of the Commissioner of Social Security
denying 	Plaintiff 	Sandi 	White’s 	claim 	for 	disability 	and 	disability
insurance benefits under Title II of the Social Security Act. The Court
has jurisdiction to review this matter pursuant to 42 U.S.C. § 1383(c)(3)
(incorporating 42 U.S.C. § 405(g) by reference). For the reasons stated
herein, the Court will affirm the decision of the commissioner.
1 Frank Bisignano became the Commissioner of Social Security on May
7, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure,
Frank Bisignano should be substituted as the defendant in this suit. No
further action is needed to continue this suit by reason of the last
sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).
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I. 	BACKGROUND
A. 	Procedural History
On December 2, 2020, White applied for disability benefits, alleging
disability beginning April 30, 2016. Transcript, Doc. 9-3 at 3. Following
an initial denial, White submitted an appeal, requesting a hearing before
an Administrative Law Judge (ALJ). Doc. 9-4 at 18. The ALJ conducted
the hearing and determined that White is not disabled. Doc. 9-2 at 30,
40.
White filed a request for review of the ALJ’s decision, which the
Appeals Council denied. Id. at 2. The ALJ’s decision, therefore, became
the final decision of the Commissioner. 42 U.S.C. § 405(g). Pending before
this Court is White’s action seeking judicial review of the Commissioner’s
decision. Complaint, Doc. 1. This case is fully briefed (docs. 10, 12, 13)
and ripe for resolution. The parties consented to the jurisdiction of a
United States Magistrate Judge to conduct all proceedings in this case,
pursuant to 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73,
including entry of final judgment. Consent Form, Doc. 7.
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B. 	The Disability Determination Process
To receive disability benefits under the Social Security Act (“Act”),
a claimant must be unable to “engage in any substantial gainful activity
by reason of any medically determinable . . . impairment which can . . .
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. § 423(d)(1)(A).
Under the Act, a claimant is disabled “only if his . . . impairments are of
such severity that he is not only unable to do his previous work but
cannot, considering his age, education, and work experience, engage in
any other kind of substantial gainful work which exists in the national
economy.” 	§ 423(d)(2)(A). 	An 	impairment 	is 	one 	that 	“results 	from
anatomical, 	physiological, 	or 	psychological 	abnormalities 	which 	are
demonstrable by medically acceptable clinical and laboratory diagnostic
techniques.” § 423(d)(3).
Social 	Security 	regulations 	provide 	a 	“five-step 	sequential
evaluation process” to determine if a claimant is disabled. 20 C.F.R.
§ 404.1520(a)(4). The claimant bears the burden of persuasion through
step four, while at step five, the burden shifts to the Secretary to show
that the claimant can perform substantial gainful employment other
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than the claimant’s past relevant work. Williams v. Sullivan, 970 F.2d
1178, 1181 (3d Cir. 1992), citing Bowen v. Yuckert, 482 U.S. 137, 146 n.5
(1987)).
At the first step, the claimant must establish that he has not
engaged in substantial gainful activity since the onset of the alleged
disability. See § 404.1520(a)(4)(i). At the second step, claimant must
establish that he suffers from a “severe medically determinable . . .
impairment that meets the duration requirement . . . (“impairment . . .
must have lasted or must be expected to last for a continuous period of at
least 12 months”).” § 404.1520(a)(4)(ii). At the third step, the claimant
must provide evidence that his impairment “meets or equals one of our
listings in appendix 1.” § 404.1520(a)(4)(iii). If the claimant demonstrates
his impairments meet those listings, he is considered to be disabled. See
id.; § 404.1520(d). If he cannot establish severity of impairment at the
third step, the eligibility analysis proceeds to step four in which the ALJ
determines whether the claimant’s residual functional capacity (“RFC”)
allows 	the 	claimant 	to 	continue 	his 	previous 	employment.
§ 404.1520(a)(4)(iv). RFC “is the most [a claimant] can still do despite”
impairments. 	§ 404.1545(a)(1). 	To 	prevail 	on 	step 	four, 	claimant’s
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“impairment(s) must prevent [him] from doing . . . past relevant work.”
§ 404.1520(f). At the fifth step, the Commissioner bears the burden to
demonstrate that the claimant’s RFC and his “age, education, and work
experience . . . [allows] adjustment to other work.” § 404.1520(a)(4)(v). If
the Commissioner cannot satisfy this burden, the claimant’s claim is
granted. See § 404.1520(g).
C. 	The ALJ’s Decision
Here, the ALJ determined that White “was not under a disability, .
. . from April 30, 2016, the alleged onset date, through December 31,
2021, the date last insured.” Doc. 9-2 at 30. 	The ALJ reached this
conclusion after proceeding through the five-step sequential analysis
required by the Social Security Act. § 404.1520(a)(4)(i)–(v); see Doc. 9-2
at 20-30.
At step one, the ALJ determined that White “did not engage in
substantial gainful activity during the period from her alleged onset date
of April 30, 2016, through her date last insured of December 31, 2021.”
Doc. 9-2 at 20. At step two, the ALJ found that White has the following
severe 	impairments: 	irritable 	bowel 	syndrome 	with 	constipation,
diverticulitis, 	gastroesophageal 	reflux 	diseases 	with 	esophagitis,
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esophageal 	hiatal 	hernia, 	chronic 	migraine, 	chronic 	tension-type
headache, asthma, thrombocytosis, iron deficiency anemia, and chronic
kidney disease. Id. At step three, the ALJ determined that White “did not
have 	an 	impairment 	or 	combination 	of 	impairments 	that 	met 	or
medically equaled the severity of one of the listed impairments in” 20
C.F.R. part 404, subpart P, appendix 1. Id. at 24.
Between steps three and four, the ALJ found that White has the
following RFC:
[T]o perform light work as defined in 20 CFR 404.1567(b)
except that the claimant is limited to occasional balancing,
stooping, kneeling, crouching, and climbing ramps and stairs,
but never crawling or climbing ladders, ropes, or scaffolds.
The claimant must avoid concentrated exposure to extreme
cold, extreme heat, humidity, vibration, and fumes, odors,
dust, gases, poor ventilation, and other pulmonary irritants.
The claimant must avoid concentrated exposure to hazards,
such 	as 	unprotected 	heights 	and 	dangerous 	moving
machinery.
Id. at 25.
At step four, the ALJ determined that White “was unable to
perform any past relevant work.” Id. at 29. At the fifth and final step, the
ALJ denied White’s disability claims because, after considering her “age,
education, work experience, and [RFC], there were jobs that exist in
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significant numbers in the national economy that the claimant could
have performed.” Id.
D. 	Issues on Appeal
White primarily argues that the ALJ’s decision, which failed to
include express standing and walking limitations in the RFC, is not
supported by substantial evidence. Pl.’s Br., Doc. 10 at 6. Specifically,
White 	argues 	that 	the 	ALJ 	failed: 	(1) 	to 	properly 	conduct 	a
function-by-function 	assessment 	of 	White’s 	standing 	and 	walking
limitations; 	(2) 	failed 	to 	include 	standing 	and 	walking 	limitations
contained within medical opinions that the ALJ found persuasive; and
(3) the RFC exceeds the limitations of the medical opinions of record. Id.
at 5.2
The Court, adhering to the deferential standard of review outlined
below, will affirm the decision of the Commissioner.
II. 	LEGAL STANDARD
In reviewing the Commissioner’s final decision denying a claimant’s
application for benefits, the Court is limited to determining whether the
2 Although White presents as distinct the third argument, it is in essence
a restatement of the first two. See doc. 10 at 15.
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findings 	of 	the 	final 	decision-maker 	are 	supported 	by 	substantial
evidence 	in 	the 	record. See 42 	U.S.C. 	§ 1383(c)(3) 	(incorporating 42
U.S.C. § 405(g) by reference); Johnson v. Comm’r of Soc. Sec., 529 F.3d
198, 200 (3d Cir. 2008); Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D.
Pa. 2012). Under the substantial-evidence standard, a court examines an
existing administrative record and asks whether it contains sufficient
evidence 	to 	support 	the 	agency’s 	factual 	determinations. 	Biestek 	v.
Berryhill, 587 U.S. 97, 102 (2019). Substantial evidence does not mean a
large or considerable amount of evidence, but rather “such relevant
evidence as a reasonable mind might accept as adequate to support a
conclusion.” Id. at 103; see also Pierce v. Underwood, 487 U.S. 552, 565
(1988). Substantial evidence is less than a preponderance of the evidence
but more than a mere scintilla. Richardson v. Perales, 402 U.S. 389, 401
(1971). A single piece of evidence is not substantial evidence if the ALJ
ignores countervailing evidence or fails to resolve a conflict created by
the evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993). In an
adequately developed factual record, however, substantial evidence may
be “something less than the weight of the evidence, and the possibility of
drawing two inconsistent conclusions from the evidence does not prevent
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[the 	ALJ’s 	decision] 	from 	being 	supported 	by 	substantial
evidence.” Consolo v. Fed. Mar. Comm’n, 383 U.S. 607, 620 (1966). “In
determining if the Commissioner’s decision is supported by substantial
evidence the court must scrutinize the record as a whole.” Leslie v.
Barnhart, 304 F. Supp. 2d 623, 627 (M.D. Pa. 2003). In reviewing the
record for substantial evidence, “[n]either the district court nor [the Third
Circuit] is empowered to weigh the evidence or substitute its conclusions
for those of the fact-finder.” Williams, 970 F.2d at 1182. To reverse the
ALJ’s findings and decision, the Court “must find that the evidence not
only 	supports 	[a 	contrary] 	conclusion 	but 	compels 	it.” 	Immigr. 	&
Naturalization Serv. v. Elias-Zacarias, 502 U.S. 478, 481 n.1 (1992).
The question before the Court, therefore, is not whether White is
disabled, but whether the Commissioner’s finding that White is not
disabled is supported by substantial evidence and was reached based
upon a correct application of the relevant law. See Arnold v. Colvin, No.
12-2417, 2014 WL 940205, at *1 (M.D. Pa. Mar. 11, 2014) (“[I]t has been
held 	that 	an 	ALJ’s 	errors 	of 	law 	denote 	a 	lack 	of 	substantial
evidence.”); Burton 	v. 	Schweiker, 	512 	F. 	Supp. 	913, 	914 	(W.D. 	Pa.
1981) (“The [Commissioner]’s determination as to the status of a claim
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requires the correct application of the law to the facts.”); see also Wright
v. Sullivan, 900 F.2d 675, 678 (3d Cir. 1990) (noting that the scope of
review on legal matters is plenary); Ficca, 901 F. Supp. 2d at 536 (“[T]he
court 	has 	plenary 	review 	of 	all 	legal 	issues 	decided 	by 	the
Commissioner.”). In determining that question, the Court must evaluate
whether the ALJ’s decision meets the burden of articulation necessary to
enable judicial review; that is, the ALJ must articulate the reasons for
his decision beyond stating bare conclusions. Burnett v. Comm’r of Soc.
Sec., 220 F.3d 112, 119 (3d Cir. 2000).
III. 	DISCUSSION
The thrust of White’s appeal is that the ALJ failed to include
standing and walking limitations in the RFC. Doc. 10 at 6. White
contends that the RFC assessment cannot be supported by substantial
evidence because: (1) the ALJ failed to make a function-by-function
assessment for White’s standing and walking limitations; and (2) omitted
both limitations from the RFC. Doc. 10 at 7, 12. Both arguments fail
under Third Circuit precedent.
First, an ALJ’s failure to perform a function-by-function analysis
alone does not require remand. Navas v. Comm’r of Soc. Sec., 289 F. App’x
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555, 557-58 (3d Cir. 2008); Chiaradio v. Comm’r of Soc. Sec., 425 F. App’x
158, 	161 	(3d 	Cir. 	2011) 	(finding 	that 	the 	ALJ’s 	RFC 	limitation 	is
supported by substantial evidence despite lacking a function by function
or task by task analysis); Garrett v. Comm’r of Soc. Sec., 274 F. App’x 159,
164 (3d Cir. 2008) (finding that, even though the ALJ failed to perform a
function-by-function analysis, the ALJ accounted for plaintiff’s testimony
in an RFC analysis regarding the plaintiff’s ability to sit and stand in her
prior work); see also McKean v. Colvin, 150 F. Supp. 3d 406, 417 (M.D.
Pa. 2015) (finding that a “function-by-function” analysis for medical
conditions was unnecessary where the ALJ considered limitations for
which there was record support).
Second, “the Third Circuit has rejected the argument that simply
limiting a claimant to light work amounts to a failure to define sitting,
standing, and walking limitations in terms of the RFC, but rather found
that such a limitation implicitly addresses these functions.” Bayarinas v.
Bisignano, No. 24-1216, 2025 WL 2550865, at *11 (M.D. Pa. Sep. 3, 2025)
(Carlson, J.) citing Navas, 289 F. App’x at 558. In Navas, the Court of
Appeals held that a light work RFC assessment implies that a claimant
can work a job that involves “a good deal of walking or standing,” or a job
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that “involves sitting most of the time with some pushing and pulling or
leg controls.” 289 F. App’x at 559, citing 20 C.F.R. § 404.1567(b). Put
differently, a determination of “light work” in the RFC implies a standing
and walking limitation for a total of six hours in an eight-hour workday.
Bayarinas, 2025 WL 2550865 at *11; Good v. Bisignano, No. 24-1158,
2025 WL 2486014, at *14 (M.D. Pa. Aug. 28, 2025) (affirming ALJ’s RFC
determination “even where the ALJ did not discuss a claimant’s ability
to sit, stand, or walk individually.”).
Here, although the ALJ did not explicitly define a standing or
walking limitation in the RFC, the ALJ’s RFC assessment is supported
by substantial evidence because it properly limited White to “light work
as defined in 20 CFR 404.1567(b).” See doc. 9-2 at 25; Navas, 289 F. App’x
at 559 (holding that an ALJ implicitly defines sitting, standing, and
walking limitations in the RFC by finding that a claimant could perform
light work as defined in 20 C.F.R. § 404.1567(b)). And a light work RFC
determination implies that White is limited to a standing and walking
limitation for a total of six of eight hours in a workday. Bayarinas, 2025
WL 2550865, at *11. “‘[T]he full range of light work requires standing or
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walking, off and on, for a total of approximately 6 hours of an 8-hour
workday.’” Id., quoting SSR 83-10, 1983 WL 31251, at *6 (S.S.A. 1983).3
Importantly, the ALJ’s “light work” RFC assessment is consistent
with and supported by two medical opinions which the ALJ found
significantly 	persuasive. 	Doc. 	9-2 	at 	28. 	Both 	Dr. 	Gandhi 	and 	Dr.
Bermudez opined that White can “stand and/or walk” six hours in an
eight-hour workday. Doc. 9-3 at 13-14, 27. And the relevant regulation
defines light work as requiring “standing or walking . . . for a total of
approximately 6 hours of an 8-hour workday.” SSR 83-10. The ALJ’s RFC
assessment, 	therefore, 	was 	supported 	by 	substantial 	evidence. 	See
Bayarinas, 2025 WL 2550865, at *11 (“Thus, since the opinion evidence
which the ALJ found persuasive did not include any more extreme or
specific sitting, standing, or walking limitations than what is already
included in the light work limitation, no more was needed here.”).
White, however, insists that the Court remand the ALJ’s decision
because it has previously done so in Barbour v. Kijakazi. Doc. 10 at 7,
3 	SSR 83-10 makes clear that an RFC to perform “light work” includes
a limitation on standing and walking to “a total of approximately 6
hours of an 8-hour workday,” not, as White suggests (without citation to
any authority) for a minimum of six hours. See Doc. 13 at 5.
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citing No. 20-861, 2021 WL 4478332, at *5 (M.D. Pa. Sept. 30, 2021). But
the Court’s decision in Barbour can be distinguished. In Barbour, the
Court’s judgment to remand was based on an ALJ’s failure to conduct a
function-by-function analysis and “the inadequacies in the ALJ’s . . .
evaluation of the medical opinion evidence[.]” Id. Whereas the ALJ in this
case found both medical opinions to be significantly persuasive (doc. 9-2
at 28), the ALJ in Barbour gave inconsistent weights to the two medical
opinions without providing an explanation, leaving the Court to guess
the ALJ’s rationale. 2021 WL 4478332 at *5. Indeed, even the Barbour
court recognized that “[a]n ALJ’s failure to conduct a function-by-function
assessment 	does 	not 	require 	remand 	where 	the 	ALJ’s 	decision 	is
otherwise supported by substantial evidence.” 	Id., citing 	Cichocki v.
Astrue, 729 F.3d 172 (2d Cir. 2013). Here, unlike in Barbour, the ALJ’s
RFC determination was consistent with the limitations suggested by the
two medical opinions he found persuasive, and is, thus, supported by
substantial evidence.
Because the ALJ’s RFC determination is supported by substantial
evidence, the ALJ’s failure to explicitly define a standing or walking
limitation does not require remand.
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IV. 	CONCLUSION
Accordingly, the Commissioner’s decision will be AFFIRMED.
An appropriate order follows.
Date: February 27, 2026 	s/Sean A. Camoni
Sean A. Camoni
United States Magistrate Judge
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