Substantial Evidence Standard-Disability Insurance Benefits

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7^th Circuit Court of Appeals

Case Name: Michael Lincoln v. Frank Bisignano

Case No.: 24-2668

Officials: Sykes, Jackson-Akiwumi and Pryor, Circuit Judges.

Focus: Substantial Evidence Standard-Disability Insurance Benefits

found  The found Lincoln sought disability insurance benefits and supplemental security income, asserting that several medical conditions, most notably prostate cancer, limited his ability to work. He began treatment in late 2019, which concluded by mid-2020, at which point his cancer went into remission. Although Lincoln reported ongoing fatigue and occasional use of a cane, he also remained capable of performing a range of daily activities. He alleged that his disability began in October 2019.

In August 2022, an Administrative Law Judge (ALJ) determined that Lincoln was not disabled. The ALJ found that Lincoln retained the residual functional capacity to perform light work with certain postural restrictions and concluded that he could return to his previous job as a school bus driver. In making this determination, the ALJ found that Lincoln’s statements about his fatigue and need for a cane were not fully supported by the medical evidence or in the daily activities he could perform. The ALJ also gave greater weight to the opinions of state agency medical consultants than to those of Lincoln’s treating nurse practitioner. The Appeals Council declined to review the case, rendering the ALJ’s decision final, and the Central District of Illinois upheld that decision.

The Seventh Circuit reviewed the case under the deferential “substantial evidence” standard. The court concluded that the ALJ’s findings, particularly regarding Lincoln’s residual functional capacity, fatigue, use of a cane, and the evaluation of medical opinions, were supported by substantial evidence, leaving the denial of benefits in place.

Affirmed.

Decided 04/23/26

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