Case Explained: ISAACSEN V. BISIGNANO

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-18 Docket: 3:24-cv-06030-DWC The Ninth Circuit affirmed the district court’s judgment upholding the Commissioner of Social Security’s denial of supplemental security income disability benefits under Title XVI of the Social Security Act. The court applied a de novo standard of review to the district court’s judgment, determining that the Commissioner’s decision would be disturbed only if it was not supported by substantial evidence or based on legal error. The court rejected the appellant’s argument that the Administrative Law Judge (ALJ) erred in finding he could perform unskilled work despite a need for five-minute hourly breaks due to physical eye fatigue. First, the court held that the Social Security Administration’s Program Operations Manual System (POMS) is not binding authority on an ALJ; therefore, the ALJ’s failure to strictly comply with POMS guidelines regarding mental limitations did not constitute legal error. Second, the court ruled that the ALJ was entitled to rely on the vocational expert’s testimony that such breaks were “not inconsistent” with allowable breaks for other employees and did not prevent the appellant from performing jobs such as cashier or routing clerk. Finally, the court clarified that an ALJ does not consider “reasonable accommodation” under the Americans with Disabilities Act (ADA) when determining disability status. Because the hourly breaks were a commonplace allowance consistent with how jobs are generally performed in the national economy, they did not constitute a reasonable accommodation requiring exclusion from the step-five analysis. The practical consequence is that the denial of disability benefits remains in effect, and the appellant receives no relief. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.