Michael Lincoln v. Frank Bisignano

── Michael Lincoln v. Frank Bisignano ── Court: Court of Appeals for the Seventh Circuit Date: April 23, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 24-2668 MICHAEL LINCOLN, Plaintiff-Appellant, v. FRANK BISIGNANO, 1 Commissioner of Social Security, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Central District of Illinois. No. 23-cv-01177 — Jonathan E. Hawley, Judge. ____________________ ARGUED MAY 14, 2025 — DECIDED APRIL 23, 2026 ____________________ Before SYKES, JACKSON-AKIWUMI and PRYOR, Circuit Judges. PRYOR, Circuit Judge. Michael Lincoln applied for disability insurance benefits and supplemental security income, alleg- ing disability beginning in October 2019. An administrative law judge (ALJ) found Lincoln was not disabled upon 1 Frank Bisignano replaced Leland Dudek as Commissioner of the Social Security Administration and is substituted as the defendant-appellee. See FED. R. APP. P. 43(c)(2). 2 No. 24-2668 concluding that his residual functional capacity (RFC) 2 would allow him to perform his past work as a school bus driver. The district court affirmed. On appeal, Lincoln challenges the ALJ’s RFC determina- tion, arguing the ALJ failed to properly evaluate evidence per- taining to Lincoln’s use of a cane and fatigue. Because sub- stantial evidence supports the ALJ’s decision, we affirm. I. BACKGROUND In his application for disability insurance benefits and supplemental security income disability benefits, Lincoln claimed that conditions including prostate cancer limited his ability to work. Lincoln began treatment for cancer in Novem- ber 2019, including chemotherapy, hormonal therapy (also re- ferred to as Lupron injections or androgen deprivation ther- apy), and radiation beam therapy. He concluded radiation beam therapy roughly six months later, in May 2020. By the following month, Lincoln’s prostate-specific antigen (PSA) levels, which signal the presence of prostate cancer, were un- detectable. Lincoln continued to receive Lupron injections every six months through May 2021. Lincoln’s prostate cancer was in remission. On May 25, 2022, ALJ Michael Hellman held a hearing on Lincoln’s application and on August 3, 2022, found Lincoln was not disabled. 2 “Residual functional capacity (‘RFC’) is an assessment of an individual’s ability to do sustained work.” Jarnutowski v. Kijakazi, 48 F.4th 769, 773 (7th Cir. 2022). “It is the most an individual can work despite his or her limita- tions or restrictions.” Id. No. 24-2668 3 The ALJ reasoned that Lincoln had the residual functional capacity to perform “light work” with certain postural limita- tions, including that he could “occasionally climb ramps or stairs; never climb ropes, ladders, and scaffolds; frequently balance and stoop; and occasionally kneel, crouch, and crawl.” This RFC, in conjunction with testimony from Lincoln and a vocational expert, allowed the ALJ to conclude that Lin- coln was able to perform his past work as a school bus driver at the light exertional level. In “reducing” Lincoln’s RFC to “light work with addi- tional postural limitations,” the ALJ found relevant Lincoln’s reports of daily fatigue stemming from his cancer treatments, as well as complaints of back and hip pain. At the same time, the ALJ decided against “rely[ing] heavily” on Lincoln’s sub- jective complaints because Lincoln’s statements about the “in- tensity, persistence and limiting effects” of his symptoms were “not entirely consistent” with other evidence in the rec- ord. For instance, the ALJ noted that despite Lincoln’s allega- tions of fat