Case Name in Social Security Case - Unavailable

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
RONALD E. D., 1
Plaintiff,
vs.
FRANK BISIGNANO, Commissioner
of Social Security, 2
Defendant.
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Case No. 3:24-cv-2526-DWD
MEMORANDUM & ORDER
DUGAN, District Judge:
This is an action under 42 U.S.C. §§ 405(g) and 1383(c) for judicial review of
Defendant 	Commissioner 	of 	Social 	Security’s 	(“Commissioner”) 	decision 	denying
Plaintiff’s applications for Disability Insurance Benefits (“DIB”) and Supplemental
Security Income (SSI”). Plaintiff’s claims were denied initially and on reconsideration.
Plaintiff asks the Court to reverse the Commissioner’s final decision and order a remand
for a new hearing. For the reasons discussed below, the final agency decision is due to be
affirmed.
I. 	Procedural History
Plaintiff filed applications for DIB and SSI on January 5, 2022, alleging disability
beginning July 27, 2018. Because a prior ALJ denied an earlier application on April 10,
1 In keeping with the Court’s practice, Plaintiff’s full name will not be used in this Memorandum
and Order due to privacy concerns. See Fed. R. Civ. P. 5.2(c) and the Advisory Committee Notes thereto.
2 Frank Bisignano became the Commissioner of Social Security on May 6, 2025. Pursuant to Rule 25(d) of
the Federal Rules of Civil Procedure, the Court DIRECTS the Clerk to substitute Frank Bisignano as the defendant
in this suit.
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2020, the relevant period for the current application begins April 11, 2020. Plaintiff’s
claims were denied initially and on reconsideration. After a haring on December 12, 2023,
ALJ Stuart Janney issued an unfavorable decision on March 27, 2024. The Appeals
Council denied review on September 20, 2024, making the decision final. Plaintiff now
seeks judicial review under 42 U.S.C. §§ 405(g) and 1383(c). To be entitled to DIB, Plaintiff
was required to establish disability on or before his date last insured of December 2023.
II. 	Applicable Legal Standards
Plaintiff is entitled to DIB if he can demonstrate he became disabled before
his Date Last Insured (“DLI”) of December 31, 2023. Liskowitz v. Astrue, 559 F.3d 736, 740
(7th Cir. 2009); 42 U.S.C. §§ 423(a)(1)(A), (c)(1). Nevertheless, “[a]n applicant who cannot
establish 	that 	she 	was disabled during 	the 	insured 	period 	for 	DIB 	may 	still
receive SSI benefits 	if 	she 	can 	establish 	that 	she 	is disabled and
has limited means.” Sienkiewicz v. Barnhart, 409 F.3d 798, 802 (7th Cir. 2005), citing 42
U.S.C. §§ 1381a, 1382; Liskowitz, 559 F.3d at 740 n.2.
To qualify for DIB and SSI, a claimant must be disabled within the meaning of the
applicable statutes. 3 A disability is defined as an inability to engage in any substantial
gainful 	activity 	by 	reason 	of 	any 	medically 	determinable 	physical 	or mental
impairment that, inter alia, 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). The claimant bears the burden of
3 The statutes and regulations pertaining to Disability Insurance Benefits (DIB) are found at 42
U.S.C. § 423, et seq., and 20 C.F.R. pt. 404. The statutes and regulations pertaining to SSI are found at 42
U.S.C. § 1382 and 1382c, et seq., and 20 C.F.R. pt. 416. As is relevant to this case, the DIB and SSI statutes
are identical. See Craft v. Astrue, 539 F.3d 668, 647, n.6 (7th Cir. 2008). For convenience, most citations herein
are to the DIB regulations.
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producing medical evidence to support the claims of disability. Eichstadt v. Astrue, 534
F.3d 663, 668 (7th Cir. 2008); see also 42 U.S.C. § 423(d)(5)(A) (“An individual shall not be
considered to be under disability unless he furnishes such medical and other evidence of
the existence thereof.”). While a claimant's statements of pain or other symptoms are
considered, those statements alone are not conclusive evidence of a disability. See 42
U.S.C. § 423(d)(5)(A); 20 C.F.R. § 404.1529.
To assess an alleged disability, the ALJ employs a “five-step sequential evaluation
process.” See 20 C.F.R. §§ 404.1520 (a)(1), (2), (4); 416.920(a)(1), (4). The ALJ asks the
following questions: (1) whether the claimant is doing substantial gainful activity; (2)
whether 	the 	claimant 	has 	a 	severe 	medically 	determinable 	physical 	or mental
impairment that meets certain duration requirements or a combination of impairments
that is severe and meets the duration requirements; (3) whether the claimant has an
impairment that meets or equals one of the impairments listed in the regulations and
satisfies the duration requirements; (4) whether, in view of the claimant's residual
functional capacity (“RFC”) and past relevant work, he or she can perform past relevant
work; and (5) whether, in view of the claimant's RFC, age, education, and work
experience, 	he 	or 	she 	can 	adjust 	to 	other 	work. See 20 	C.F.R. 	§§ 	404.1520(a)(4);
416.920(a)(4); see also Young v. Barnhart, 362 F.3d 995, 1000 (7th Cir. 2004).
If the claimant is doing substantial gainful activity under step 1, does not have an
impairment or combination of impairments as described at step 2, can perform past
relevant work under step 4, or can adjust to other work under step 5, then the claimant is
not disabled. See 20 C.F.R. §§ 404.1520(a)(4)(i),(ii), (iv), (v); 416.920(a)(4)(i), (ii), (iv), (v). If
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the claimant has an impairment that meets the requirements of step 3 or is incapable of
adjusting to other work under step 5, then he or she is disabled. See 20 C.F.R. §§
404.1520(a)(4)(iii),(v); 416.920(a)(4)(iii), (v). The claimant has the burden of proof at steps
1-4. Mandrell v. Kijakazi, 25 F.4th 514, 516 (7th Cir. 2022).
A severe impairment under step 2 is defined as “any impairment or combination
of impairments which significantly limits [the claimant's] physical or mental ability to do
basic work activities.” §§ 404.1520(c), 416.920(c); see also Barnhart v. Thomas, 540 U.S. 20,
124 S. Ct. 376, 157 L. Ed. 2d 333 (2003). Impairments which are expected to result in death,
or those which have lasted or are expected to last for a continuous period of at least twelve
months, qualify as severe under the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii);
404.1509; 416.920(a)(4)(ii); 416.909. “[T]he step two determination of severity is ‘merely a
threshold 	requirement’ 	” 	to 	“proceed 	to 	the 	remaining 	steps 	of 	the 	evaluation
process.” Castile v. Astrue, 617 F.3d 923, 926-27 (7th Cir. 2010). Once an ALJ makes a
finding that one or more of a claimant's ailments are severe, he must “consider the
aggregate effect of the entire constellation of ailments—including those impairments that
in isolation are not severe.” Golembiewski v. Barnhart, 322 F.3d 912, 918 (7th Cir.
2003) (citing 20 C.F.R. § 404.1523; and then collecting cases).
Impairments and related symptoms may cause physical and mental limitations
that 	affect 	what 	may 	be 	done in 	a 	work 	setting. See 20 	C.F.R. 	§§ 	404.1545(a)(1);
416.945(a)(1). The RFC at issue in step 4 assesses the most that a claimant can do in a work
setting, 	notwithstanding 	those 	limitations. See 20 	C.F.R. 	§§ 	404.1545(a)(1);
416.945(a)(1); accord SSR 96-8p, 1996 WL 374184, *2; Clifford v. Apfel, 227 F.3d 863, 872-73
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n.7 (7th Cir. 2000). In this way, an RFC is an assessment of the claimant's ability to perform
sustained work-related physical and mental activities in a work setting on a regular and
continuing basis, i.e., for eight hours a day and five days a week or an equivalent work
schedule. See Tenhove v. Colvin, 97 F. Supp. 2d 557, 568 (E.D. Wisc. 2013); SSR 96-8p, 1996
WL 374184, *2; accord Moore v. Colvin, 743 F.3d 1118, 1121 (7th Cir. 2014). An RFC must be
based on all of the relevant medical and other evidence contained in the record. See 20
C.F.R. §§ 404.1545(a)(3); 416.945(a)(3); SSR 96-8p, 1996 WL 374184, *2-3, 5.
When completing an RFC, the ALJ must identify the claimant's functional
limitations and assess his or her work-related abilities on a function-by-function
basis. See Tenhove, 97 F. Supp. 2d at 569; SSR 96-8p, 1996 WL 374184, *1, 3; accord Lechner
v. Barnhart, 321 F. Supp. 2d 1015, 1036 (E.D. Wisc. 2004). The ALJ considers all
impairments, including those that are not severe, and the claimant's ability to meet
physical, 	mental, 	sensory, 	and 	other 	requirements 	of 	work. See 20 	C.F.R. 	§§
404.1545(a)(2), (4); 416.945(a)(2), (4); see also Alesia v. Astrue, 789 F. Supp. 2d 921, 933 (N.D.
Ill. 2011) (“[T]he ALJ must consider the combined effect of all impairments, ‘even those
that would not be considered severe in isolation.’ ”). “An impairment or combination of
impairments is not severe if it does not significantly limit [the] physical or mental ability
to do basic work activities.” 20 C.F.R. § 404.1522(a). And, importantly, while a claimant's
statements of pain or other symptoms are considered, they alone are not conclusive
evidence of a disability. See 20 C.F.R. § 404.1529.
As to physical abilities, the ALJ assesses the nature and extent of any physical
limitations, then determines the RFC for work activity on a regular and continuing
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basis. See 20 C.F.R. §§ 404.1545(b); 416.945(b). A limited ability to perform physical
demands of work activity, such as sitting, standing, walking, lifting, carrying, pushing,
pulling, reaching, handling, stooping, or crouching may reduce the ability to do past
work. See 20 C.F.R. §§ 404.1545(b); 416.945(b); see also SSR 96-8p, 1996 WL 374184, *5-6.
Other impairments affecting work abilities include, among other things, impairments
imposing environmental restrictions. See 20 C.F.R. §§ 404.1545(d); 416.945(d). If the
symptoms, signs, or laboratory findings for a severe impairment do not meet or equal
those 	of 	a 	listed 	impairment, 	the 	ALJ 	considers 	the 	total 	limiting 	effects 	of 	all
impairments, including medical and nonmedical evidence. 20 C.F.R. §§ 404.1545(e);
416.945(e).
After the identification of the claimant's functional limitations and the assessment
of his or her work abilities on a function-by-function basis, the RFC may be expressed by
exertional category, including “light.” See Tenhove, 97 F. Supp. 2d at 569; accord Lechner,
321 F. Supp. 2d at 1036; SSR 96-8p, 1996 WL 374184, *3. To do a full range of work in an
exertional category, such as “light,” the individual must be able to perform substantially
all of the functions required at that level. See SSR 96-8p, 1996 WL 374184, *5-6. Light work
involves “lifting no more than 20 pounds at a time with frequent lifting or carrying of
objects weighing up to 10 pounds.” 20 C.F.R. §§ 404.1567(b); 416.967(b). Even the weight
lifted in a job is very little, a job is considered light work if it requires a good deal of
walking or sitting, or sitting most of the time with some pushing and pulling of arm or
leg controls. See 20 C.F.R. §§ 404.1567(b); 416.967(b). In the absence of additional limiting
factors like “loss of fine dexterity or inability to sit for long periods of time,” a person
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considered capable of performing light work is also considered capable of performing
sedentary work. See 20 C.F.R. §§ 404.1567(b); 416.967(b).
III. 	The Decision of the ALJ
The ALJ followed the five-step analytical framework described above. At step one,
she determined that Plaintiff had not engaged in substantial gainful activity since the
alleged disability onset date, and that he meets the insured status requirements of the
SSA through December 31, 2023. (Doc. 11-2, pg. 12). Plaintiff was 52 years old on the
alleged onset date (Doc. 11-2, pg. 29). At step two, the ALJ found that Plaintiff has the
following severe impairments: major depressive disorder, bipolar disorder, and anxiety
disorder. (Doc. 11-2, pg. 14). The ALJ found that Plaintiff has the following non-severe
impairments: lumbar and cervical spine degenerative disc disease, right ankle spur,
allergic rhinitis, hypertension, hyperlipidemia, hepatic steatosis and pancreatitis, chronic
kidney disease, anemia, diabetes mellitus, obesity, and headache disorder. (Doc. 11-2, pg.
14). The ALJ found that the following conditions, for which claimant alleged a diagnoses,
are 	not 	medically 	determinable: 	bilateral 	knee 	pain, 	shoulder 	pain, 	hand 	pain,
paresthesias, schizophrenia, post-traumatic stress disorder, and chronic pain. (Doc. 11-2,
pg. 15).
At step three, the ALJ found that Plaintiff does not have any impairments or
combination of impairments that meet any of the listings. (Doc. 11-2, pg. 15). 	The ALJ
determined that Plaintiff has a moderate limitation in his ability to understand,
remember, or apply information. He found that Plaintiff has a moderate limitation in his
ability to interact with others. The ALJ also concluded that Plaintiff has a moderate
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limitation in his ability to concentrate, persist, or maintain pace. Finally, the ALJ found
that Plaintiff has only a mild limitation in his ability to adapt and manage himself. (Doc.
11-2, pgs. 14-18).
Before proceeding to step four, the ALJ assessed Plaintiff’s residual functional
capacity (“RFC”) and concluded that he was able to:
perform a full range of work at all exertional levels but with the following
nonexertional limitations. He can understand, carry out, and remember
simple 	and 	detailed 	but 	not 	complex 	instructions. 	He 	can 	tolerate
occasional interactions with supervisors, coworkers, and the public and can
respond appropriately during the interactions.
(Doc. 11-2, pg. 17).
Next, the ALJ concluded that given Plaintiff’s RFC and the vocational expert’s
(“VE”) testimony, Plaintiff was unable to perform his past jobs as a Home Attendant (step
4), but he could perform other work that existed in the national economy (step 5). (Doc.
11-2, pgs. 29-30). 4 As a result, the ALJ found that Plaintiff was not disabled. (Doc. 11-2,
pg. 30).
IV. 	Standard of Review and Plaintiff’s Arguments 5
The Court's review of the ALJ's decision is “extremely limited” and “very
deferential.” See 42 U.S.C. § 405(g); Jarnutowski v. Kijakazi, 48 F.4th 769, 773 (7th Cir.
2022) (quoting Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008)). Findings of fact,
supported by substantial evidence, are conclusive. See 42 U.S.C. § 405(g); accord Clifford,
4 The VE testified Plaintiff would be able to perform the following jobs: (1) kitchen helper (medium
exertion and unskilled); hospital cleaner (medium exertion and unskilled); and (3) laundry laborer (medium exertion
and unskilled). (Doc. 11-2, pg. 30).
5 The portions of the evidentiary record relevant to Plaintiff's arguments and the Court's resolution of the
case are incorporated into the analysis below.
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227 F.3d at 869. The Court will reverse the ALJ's decision only if the findings of fact were
not 	supported 	by 	substantial 	evidence 	or 	the 	ALJ 	applied 	the 	wrong 	legal
standard. See Clifford, 227 F.3d at 869; accord Martin v. Saul, 950 F.3d 369, 373 (7th Cir.
2020). 	In 	this 	context, 	“substantial 	evidence 	means 	‘such 	relevant 	evidence 	as 	a
reasonable mind might accept as adequate to support a conclusion.’ ” See Clifford, 227
F.3d at 869 (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)); accord Jarnutowski, 48
F.4th at 773. If reasonable minds could differ about whether a claimant is disabled and
the ALJ's decision is supported by substantial evidence, then the Court will affirm the
denial of claims. Jarnutowski, 48 F.4th at 773 (quoting Elder, 529 F.3d at 413). When
assessing the evidence, the Court reviews the entire record, but does not reweigh the
evidence, resolve conflicts, decide credibility questions, or substitute its judgment for that
of the ALJ. See Clifford, 227 F.3d at 869; accord Lopez ex rel. Lopez v. Barnhart, 336 F.3d 535,
539 (7th Cir. 2003). The ALJ is not required to address every piece of evidence or
testimony presented, but he must build a ‘logical bridge’ between the evidence and his
conclusions. Terry v. Astrue, 580 F.3d 471, 475 (7 th Cir. 2009); see also Gedatus v. Saul, 994
F.3d 893, 901 (7th Cir. 2021) (“The ALJ's summary does not mention every detail. But it
need not.”). An ALJ is not permitted to “cherry pick evidence from the record” to support
a conclusion without engaging with evidence weighing against it. Plessinger v. Berryhill,
900 F.3d 909, 915 (7th Cir. 2018). The Court will not decline to engage in a critical review
to act as a rubber stamp. See Clifford, 227 F.3d at 869.
Plaintiff makes three arguments in support of reversal of the Commissioner’s
decision:
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1. 	The ALJ’s evaluation of Plaintiff’s subjective statements was legally insufficient
because the ALJ failed to properly evaluate the relevant regulatory factors, as
required by 20 C.F.R. §§ 404.1529 and 416.929 and SSR 16-3p.
2. 	The ALJ’s evaluation of Plaintiff’s mental RFC was legally insufficient and his
conclusion that Plaintiff could manage simple and detailed tasks, but not
complex tasks, and occasional interaction with supervisors, coworkers, and the
public is not supported by substantial evidence.
3. 	The ALJ’s physical RFC assessment was not supported by substantial evidence
because he failed to analyze the combined impact of Plaintiff’s lumbar
degenerative disc disease and obesity.
V. 	Analysis
A. Evaluation of Subjective Symptoms
Plaintiff argues that the ALJ’s evaluation of his subjective statements was legally
insufficient because the ALJ failed to properly evaluate the relevant regulatory factors
under 20 C.F.R. §§ 404.1529 and 416.929 and SSR 16-3p. Specifically, Plaintiff contends
that the ALJ did not expressly address “many” of the regulatory factors, such as
aggravating or precipitating factors for his pain, the effectiveness or side effects of
medications, non-treatment measures for symptom relief, and aspects of his mental
health functioning like treatment history, lack of insight into his illness, and the minimal
effectiveness of prescribed medications. Plaintiff further criticizes the ALJ for not
explicitly explaining how objective medical findings undermined his statements about
back pain, asserting that such findings (e.g., mild spinal impairments on imaging) do not
correlate 	with 	specific 	pain 	levels 	and 	thus 	fail 	the 	“logical 	bridge” 	standard.
Additionally, Plaintiff faults the ALJ for inadequately considering the impact of his
obesity on pain, and for noting conservative treatment without detailing how it factored
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into discounting his claims, including omitting discussion of a one-time five-day
prescription for Norco following a back pain complaint after lifting a heavy object. These
arguments lack merit. The ALJ’s evaluation was reasonable, supported by substantial
evidence, and compliant with the regulations.
An ALJ’s assessment of a claimant’s subjective symptoms is entitled to significant
deference and will be reversed only if “patently wrong,” meaning it lacks any explanation
or support. Hess v. O’Malley, 92 F.4th 671, 679 (7th Cir. 2024); Grotts v. Kijakazi, 27 F.4th
1273, 1278 (7th Cir. 2022). Subjective statements about pain or other symptoms are not
conclusive evidence of disability and must be supported by objective evidence. 42 U.S.C.
§ 423(d)(5)(A); Grotts, 27 F.4th at 1278. When a claimant’s statements are not substantiated
by objective medical evidence alone, the ALJ must consider regulatory factors such as the
nature and intensity of symptoms; precipitating or aggravating factors; relieving factors;
dosage and effectiveness of medications; treatment history; non-treatment measures;
physicians’ opinions or observations; functional restrictions; prior work record; daily
activities; and other relevant factors. 20 C.F.R. §§ 404.1529(c), 416.929(c); SSR 16-3p;
Zurawski v. Halter, 245 F.3d 881, 887-88 (7th Cir. 2001). However, the ALJ need not
mechanically discuss every factor or detail, nor address every piece of evidence. Gedatus
v. Saul, 994 F.3d 893, 903 (7th Cir. 2021) (”[A]n ALJ need not discuss every detail related
to every factor.”); Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024) (no requirement
to cite support for every proposition or fully summarize the record). Summaries of
medical evidence may be “partial and selective” yet still appropriate. Grotts, 27 F.4th at
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1278 (citing Gedatus, 994 F.3d at 901). The decision, which should be read holistically,
must simply build a discernible “logical bridge” between the evidence and conclusions.
Terry v. Astrue, 580 F.3d 471, 475 (7th Cir. 2009); Zellweger v. Saul, 984 F.3d 1251, 1252, 1254
(7th Cir. 2021). The claimant bears the burden of proving limitations, Prill v. Kijakazi, 23
F.4th 738, 746 (7th Cir. 2022), and a lack of supporting medical opinions setting “any other
limits, 	greater 	than 	those 	the 	ALJ 	set” 	is 	a 	“fundamental 	problem.”
Gedatus, 994 F.3d at 904-05.
The ALJ properly applied this framework. He first acknowledged that Plaintiff’s
medically determinable impairments (severe mental health conditions and non-severe
physical impairments like degenerative disc disease and obesity) could reasonably cause
his alleged symptoms. (Doc. 11-2, pg. 22). However, he found Plaintiff’s statements about
their intensity, persistence, and limiting effects (e.g., standing only a few minutes,
walking a couple of blocks, lifting no more than eight pounds, constant back and knee
pain, severe anxiety, PTSD, memory and concentration issues, paranoia, and frustration
with social interactions) to be “generally inconsistent” with the record. (Doc. 11-2, pgs.
23-24). The ALJ built a logical bridge by contrasting Plaintiff’s subjective complaints with
objective evidence, treatment history, and daily activities. This meets the minimal
articulation requirement. See Hess v. O’Malley, 92 F.4th 671, 679 (7th Cir. 2024) (reversal
requires 	the 	decision 	to 	be 	“patently 	wrong,” 	meaning 	the 	decision 	“lacks 	any
explanation or support.”); Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024) (the ALJ
satisfies minimal articulation by providing reasoned support without needing to address
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every piece of evidence, fully summarize the record, or cite every reasoning chain);
Zellweger v. Saul, 984 F.3d 1251, 1252 (7th Cir. 2021) (courts review ALJ decisions
holistically to assess if the path of reasoning is discernible, without requiring exhaustive
detail); Elder v. Astrue, 529 F.3d 408, 413-14 (7th Cir. 2008) (clarifying that minimal
articulation is met if the determination is reasoned and supported, with reversal only for
decisions lacking any explanation or support).
Contrary to Plaintiff’s assertion, the ALJ adequately considered the regulatory
factors to the extent relevant. For the nature and intensity of symptoms, the ALJ
contrasted Plaintiff’s extreme physical claims (e.g., debilitating pain since 2018, knees
“giving out,” inability to sit in a car) with consistently mild or normal objective findings,
including mild spondylosis (July 2018 imaging) (Doc. 11-2, pg. 23); mild degenerative
arthrosis of the right first MTP joint and a small spur (March 2019 imaging) (Doc. 11-2,
pg. 23); no acute low-back abnormalities (exam following 2021 back pain complaints)
(Doc. 11-2, pg. 23); mild degenerative changes (January 2022 lumbar spine imaging) (Doc.
11-2, pg. 23); mild multilevel degenerative changes (June 2022 cervical spine imaging)
(Doc. 11-2, pg. 24); no spinal deformities or motion limits in the August 2022 consultative
exam with Dr. Feinerman (plus normal ambulation without device, gait, muscle strength,
reflexes, and negative straight-leg raises) (Doc. 11-2, pgs. 21-23); and no abnormalities in
the 2023 primary care exam related to acute pain following lifting a stove. Objective
medical evidence is a “useful indicator” for assessing symptom intensity and persistence,
20 C.F.R. § 404.1529(c)(2), and “a discrepancy between the degree of pain claimed by the
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applicant 	and 	that 	suggested 	by 	medical 	records 	is 	probative 	of 	exaggeration.”
Sienkiewicz v. Barnhart, 409 F.3d 798, 803-04 (7th Cir. 2005). The ALJ explicitly noted that
the state-agency medical consultants found Plaintiff suffered from no severe physical
impairments (Doc. 11-2, pg. 23; Doc. 11-4, pgs. 40, 64). The ALJ further found these
opinions 	to 	be 	consistent 	with 	the 	objective 	medical 	evidence, 	persuasive, 	and
inconsistent with Plaintiff’s subjective complaints. (Doc. 11-2, pg. 23). No expert opinion
corroborated 	greater 	limitations, 	bolstering 	the 	ALJ’s 	findings. 	See
Gedatus, 994 F.3d at 904-05.
For mental symptoms (e.g., anxiety, depression, memory issues, paranoia), the
ALJ addressed intensity through treatment records showing limited complaints and
normal 	exams 	(Doc. 	11-2, 	pgs. 	20-23), 	without 	needing 	separate 	factor-by-factor
discussion for each impairment. See Warnell, 97 F.4th at 1053-54.
Regarding treatment and relieving factors, including medications, efficacy, and
non-treatment measures, the ALJ reasonably highlighted Plaintiff’s sparse, conservative
care as inconsistent with disabling symptoms. Minimal or routine treatment can
undermine claims of extreme symptoms. Deborah M. v. Saul, 994 F.3d 785, 789 (7th Cir.
2021); Craft v. Astrue, 539 F.3d 668, 679 (7th Cir. 2008); Sienkiewicz, 409 F.3d at 803-04. For
instance, the ALJ noted no musculoskeletal treatment until the 2023 heavy-lifting
incident, refusal to 	discuss surgery or consider conservative options like steroid
injections, 	limited 	physical 	therapy 	(despite 	claiming 	it 	unhelpful), 	and 	overall
“unremarkable” records with no surgical indications. (Doc. 11-2, pgs. 24-25). This directly
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addresses 	treatment 	efficacy 	and 	relieving 	factors, 	as 	gaps 	and 	refusals 	suggest
symptoms were not as persistent as alleged.
Plaintiff’s criticism that the ALJ omitted a one-time five-day Norco prescription is
unavailing; the ALJ need not discuss every detail, Books v. Chater, 91 F.3d 972, 980 (7th
Cir. 1996), and this brief, post-incident prescription aligns with conservative care and
does not contradict the ALJ’s conclusions. Similarly, the ALJ addressed functional
restrictions and observations by noting Plaintiff’s rare reports of activity limitations to
providers and noting he only mentioned significant ones when discussing disability
benefits. Factors that are inconsistent with Plaintiff’s subjective complaints. (Doc. 11-2,
pg. 23).
Plaintiff’s obesity argument fares no better. The ALJ acknowledged BMI in the 30s
(non-extreme obesity) and its potential to exacerbate pain but found no objective
evidence 	of 	greater 	limitations 	on 	musculoskeletal, 	respiratory, 	or 	cardiovascular
functioning. (Doc. 11-2, pg. 23). This is sufficient, as speculation about obesity’s impact is
inadequate; Plaintiff must show specific limitations, which he did not testify to, and no
provider opined any. Prochaska v. Barnhart, 454 F.3d 731, 736-37 (7th Cir. 2006); see also
Dornseif v. Astrue, 499 Fed. App’x. 598, 600 (7th Cir. 2013) (failure to explain obesity’s
work impact renders omission harmless). Unrefuted state-agency notes on mild obesity
reinforce the ALJ’s analysis. (Doc. 11-4, pgs. 39-40, 64-65).
Finally, the ALJ considered daily activities and other factors, noting Plaintiff’s
reports of enjoying vehicle/yard work, cruising with his wife, hiking, camping, tracking,
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driving, and shopping alone, activities conflicting with the alleged severity of Plaintiff’s
physical and mental symptoms. (Doc. 11-2, pgs. 16-17, 21; Doc. 11-21, pg. 39). Such
inconsistencies support the ALJ’s decision to discount the alleged severity of Plaintiff’s
symptoms. 20 C.F.R. § 404.1529(c)(3)(i); see also Shideler v. Astrue, 688 F.3d 306, 312 (7th
Cir. 2012) (credibility findings need not specify every inconsistent statement). The ALJ
also noted no medical necessity for an assistive device, despite claims of cane use. (Doc.
11-2, pg. 24).
In sum, reading the decision holistically, the ALJ built a discernible logical bridge:
Plaintiff’s subjective complaints were discounted because they conflicted with objective
evidence, unrefuted state-agency opinions, sparse and conservative treatment, minimal
provider-reported restrictions, and inconsistent activities. The ALJ’s evaluation was not
patently wrong, unreasonable, or unsupported, but backed by substantial evidence, and
a reasonable mind could accept it as adequate. Accordingly, remand is not warranted on
Claim 1.
B. Mental RFC EVALUATION
1. 	Preliminary Matter
As a preliminary matter, the Court addresses the Commissioner’s argument
regarding the relevance of the RFC’s limitation to detailed work. The RFC restricted
Plaintiff to simple (unskilled) and detailed (semi-skilled) work, with no limitations on
task pace. The Commissioner asserts that because the VE identified three unskilled jobs
that Plaintiff could perform (Doc. 11-2, pgs. 30, 81), the ALJ’s decision stands absent
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persuasive evidence that Plaintiff cannot perform simple, unskilled work, rendering the
detailed-work limitation irrelevant.
The Commissioner is correct to the extent that the detailed-work limitation does
not affect the outcome if substantial evidence supports the ALJ’s finding that Plaintiff can
perform the identified unskilled jobs. See 20 C.F.R. § 404.1578(a) (defining unskilled work
as involving “little or no judgment to do simple duties”). The ALJ specifically found that
Plaintiff could manage the complexity and pace of such unskilled work. (Doc. 11-2, pgs.
18, 27, 30, 81). The Court therefore examines whether substantial evidence supports
Plaintiff’s ability to perform simple, unskilled work. Because the Court concludes that it
does, it need not determine whether the ALJ also properly found Plaintiff capable of semi-
skilled or detailed work, as any error on that point would be harmless. See Diaz v. Chater,
55 F.3d 300, 307 (7 th Cir. 1995) (error in assessing capacity for light work harmless where
substantial evidence supported sedentary work, sufficing for non-disability finding);
Cooley v. Berryhill, 738 F. App'x 877, 881 (7th Cir. 2018) (error at step four harmless due to
alternative step five finding); cf. Jill A. W. v. Kijakazi, No. 20 C 3854, 2023 WL 2954919, at
*3 (N.D. Ill. Apr. 14, 2023) (declining harmless error for step four without ALJ’s
alternative step five finding, as courts cannot invent rationales). Unlike in Jill, the ALJ’s
step five conclusion here relies directly on the VE’s unskilled jobs and Plaintiff’s
supported capacity for them, without requiring the Court to hypothesize unarticulated
findings.
2. 	Plaintiff’s Arguments
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The Plaintiff asserts that the administrative law judge’s mental residual functional
capacity determination, which limited him to simple and detailed but not complex tasks
with occasional interactions, was legally insufficient and lacked substantial evidentiary
support, 	thereby 	requiring 	remand. 	The 	Plaintiff 	specifically 	contends 	that 	the
administrative law judge erred by failing to: (1) identify the particular problems giving
rise to the moderate limitations in concentration, persistence, or pace and explain how
the residual functional capacity accommodated those limitations; (2) connect the state-
agency 	consultants’ 	opinions 	permitting 	unskilled 	and 	semi-skilled 	work 	to 	the
formulation of the residual functional capacity; (3) quantify the frequency of the
Plaintiff’s need for redirection and confront the vocational expert’s testimony that even
one instance of daily redirection after training would preclude all work; and (4) address
evidence from the August 2022 consultative examination concerning agitation and anger.
Additionally, the Plaintiff suggests that restrictions to simple tasks are inherently
incompatible with moderate limitations in concentration, persistence, or pace, invoking
pre-2017 Seventh Circuit precedent such as O’Connor-Spinner v. Astrue, 627 F.3d 614 (7th
Cir. 2010).
As is set forth more fully below, remand is not warranted. The administrative law
judge’s assessment complied with the applicable regulations and rulings, constructed a
logical bridge between the evidence and the conclusions reached, and rested upon
substantial evidence.
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3. 	Accommodation of Moderate Limitations in Concentration, Persistence, or
Pace
At step three, the ALJ found moderate limitations in concentration, persistence, or
pace, relying on the persuasive opinions of state agency psychologists. (Doc. 11-2, pgs.
17, 26; Doc. 11-4, pgs. 43-44, 68-69). 6 Consistent with the 2017 amendments to the
regulations, a “moderate” limitation means that Plaintiff’s functioning in this area,
independently, appropriately, effectively, and on a sustained basis is “fair” rather than
poor or inadequate. 20 C.F.R. Pt. 404, Subpt. P, App. 1, § 12.00F(2)(c). The ALJ accounted
for this limitation by restricting Plaintiff’s RFC to simple and detailed, but not complex,
instructions and to occasional interaction with supervisors, coworkers, and the public.
(Doc. 11-2, pg. 18). Such a formulation is not insufficient as a matter of law. Although
O’Connor-Spinner cautions that simple-work limitations do not always address deficits in
concentration, persistence, or pace, subsequent Seventh Circuit decisions under the
amended regulations clarify that moderate limitations in this area are not inherently
inconsistent with a residual functional capacity for simple, routine, repetitive tasks when
supported by narrative medical evidence. See Pavlicek v. Saul, 994 F.3d 777, 783 (7th Cir.
6 The state-agency psychologists rated Plaintiff as being moderately limited in his ability to carry out detailed
instructions and in his ability to maintain attention and concentration for extended periods. Plaintiff received a rating
of “not significantly limited” for all other categories. (Doc. 11-4, pgs. 43, 68). The state-agency psychologists narrative
explained as follows:
Per results of testing of didactic items in mental status as conducted by [the consultative
psychologist] attentional skills are intact and adequate for unskilled as well as semi-skilled tasks.
CT performs reasonably well on cognitive tasks on MSE that sample skills of attending, persistence,
and pace (digit recall, serial 3’s & backwards spelling). Report of observations regarding persistence
during CE describe good participation in interview. Carries out a fair range of daily activities w
complaints of physical limitations. On report of daily functioning, CT is described w some limitation
of attention. Symptoms of depression/anxiety moderately limit ability to manage complex tasks.
(Doc. 1104, pgs. 44, 68).
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2021) (holding that a moderate CPP limitation is “consistent with the ability to perform
simple, repetitive tasks at a consistent pace” where supported by consultants’ narrative
findings); Hess, 92 F.4th at 679 (affirming an RFC for “simple, routine, and repetitive
tasks” with no production quotas where it corresponded to moderate CPP limitations
and “fair” functioning).
Here, the ALJ provided a detailed explanation linking the evidence to the RFC,
thereby eliminating any need for remand. (Doc. 11-2, pgs. 17, 25-29). He prioritized the
state-agency psychologists’ narrative assessments over checklist ratings, consistent with
agency guidance. POMS DI 24510.060(B)(2)(a) (providing that ratings serve merely as a
worksheet to aid in determining functional restrictions). Those narratives indicated that
the Plaintiff’s attentional skills were intact and adequate for unskilled as well as semi-
skilled tasks; that symptoms moderately limited his ability to manage complex tasks; that
he should observe moderate limitations in social expectations; and that he could engage
in unskilled and semi-skilled productive activity with modified social demands. (Doc. 11-
4, pgs. 43-44, 68-69). Significantly, the psychologists rated Plaintiff as not significantly
limited in completing a normal workday and workweek without interruptions from
psychologically based symptoms or in performing at a consistent pace without an
unreasonable number and length of rest periods. (Doc. 11-4, pg. 43, 68). 	By equating
simple tasks to unskilled duties, the administrative law judge reasonably interpreted the
opinions as addressing limitations in 	concentration, persistence, or pace through
restrictions on task complexity rather than on pace or persistence, a permissible
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approach. See Pavlicek, 994 F.3d at 783 (narratives “adequately encapsulate[d] and
translate[d]” moderate checklists where they specified consistent pace for simple tasks);
Keith K. v. O’Malley, No. 23 CV 1622, 2024 WL 4723622, at *7-8 (N.D. Ill. Nov. 8, 2024)
(affirming similar translation, noting no need to restrict each CPP sub-area under §
12.00F.3.f).
Plaintiff maintains that reversal is required because the ALJ did not explicitly
delineate the problems underlying the moderate rating in concentration, persistence or
pace. However, the regulations do not mandate dissection of each sub-area when the
overall rating is moderate and the residual functional capacity holistically accounts for
the evidence. § 12.00F.3.f (“it is not necessary to articulate the rating for each individual
part”). Here, the logical bridge is apparent: the state-agency psychologists linked any
difficulties, such as moderate issues with extended attention, to complex tasks rather than
to persistence in unskilled work, and the record revealed no needs related to pace. See
Burmester v. Berryhill, 920 F.3d 507, 511 (7th Cir. 2019) (ALJ permissibly relied on expert’s
narrative that concentration was “manageable” for simple instructions). No apparent
conflict necessitates remand, as the administrative law judge resolved any perceived
inconsistencies by deferring to the narratives and the overall record.
4. 	Redirection and Persistence Needs
The 	administrative 	law 	judge 	recognized 	the 	Plaintiff’s 	difficulties 	with
redirection but concluded that such needs were infrequent, responsive to intervention,
exceptional in nature, and limited to more complex matters. These difficulties did not
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necessitate additional restrictions in the residual functional capacity for simple, unskilled
work. (Doc. 11-2, pp. 17, 25-27). In support of this determination, the administrative law
judge cited Plaintiff’s daily activities, which included driving, shopping, watching
television and movies, preparing meals, doing laundry, managing finances, vacuuming,
making household repairs, and 	using the 	internet. These activities demonstrated
persistence without disruption in simpler tasks. (Doc. 11-2, pp. 17, 27). The administrative
law 	judge 	further 	observed 	that 	treatment 	records 	documented 	only 	infrequent
redirection, to which the Plaintiff responded well, and that neither the consultative
psychologist nor the treatment providers suggested any need for shortened sessions,
extra breaks, or comparable accommodations due to symptoms. (Doc. 11-2, pp. 17, 27).
Additionally, the administrative law judge relied upon the state-agency psychologists,
who reviewed the consultative examination, including notations of tangential thought
processes and difficulty with redirection, yet determined that cognitive limitations
impacted only complex work, not simple or unskilled tasks. (Doc. 11-2, pp. 17, 25-27; Doc.
11-4, pp. 38, 41-43, 67-69). The Plaintiff, who bears the burden of establishing not just the
existence of conditions, but of providing evidence that those conditions support specific
limitations in his capacity to work, presented no opposing assessment or other evidence
indicating that redirection was required for the completion of simple, unskilled tasks. See
Weaver v. Berryhill, 746 F. App’x 574, 579 (7th Cir. 2018).
Contrary to the Plaintiff’s contention, the administrative law judge was not
obligated to specifically address the vocational expert’s testimony regarding once-daily
redirection, as that testimony arose solely in response to a hypothetical limitation that the
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administrative law judge did not adopt in the RFC. Vocational experts provide
information on the kinds of work a hypothetical person with certain limitations can
perform but do not opine on a claimant’s RFC or resolve factual disputes. See HALLEX
I-2-6-74; Pagos v. Colvin, No. 13 CV 4430, 2015 WL 1502923, at *7 (N.D. Ill. Mar. 27, 2015)
(explaining that VE testimony pertains to hypothetical individuals with given RFCs, not
to a claimant’s specific condition or limitations). An ALJ commits no error by omitting
discussion of alternative hypotheticals that include limitations ultimately deemed
unsupported by the record. See Grant A.G. v. Comm’r of Soc. Sec., No. 120CV01209JESJEH,
2021 WL 8444634, at *7 (C.D. Ill. Oct. 19, 2021) (rejecting claim that ALJ must discuss VE
testimony on unadopted hypotheticals, as VE opinions are not binding and must be
weighed with other evidence), report and recommendation adopted, No. 20-CV-1209-
JES-JEH, 2022 WL 989472 (C.D. Ill. Apr. 1, 2022).
5. 	Social Functioning, Agitation, and Anger
The Plaintiff argues that the administrative law judge overlooked treatment
records and consultative notes concerning the Plaintiff’s struggles with anger, lashing
out, and interactions with others. However, the administrative law judge discussed both
the 	treatment 	notes 	and 	the 	consultative 	psychologist’s 	observations 	regarding
occasional outbursts of anger or aggression. (Doc. 11-2, pp. 16-17, 20, 22, 25). The
administrative law judge noted that, although the Plaintiff became angry at times and
expressed it through loudness, he was never discharged by a medical provider or warned
about inappropriate conduct. The record further reflected that, despite occasional
outbursts, the Plaintiff established rapport with treatment providers and interacted with
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the community sufficiently to meet his needs. Additionally, while the consultative
examiner noted aggressive thought processes, the Plaintiff’s demeanor was described as
pleasant, his behavior and ability to relate as normal, and his affect as superficially bright.
(Doc. 11-2, pp. 16-17, 20, 22, 25). The administrative law judge reasonably deferred to the
state-agency psychologists, both of whom reviewed the consultative examination and
acknowledged the aggressive thought processes alongside the pleasant demeanor and
bright affect. They concluded that the Plaintiff had moderate limitations in social
expectations, meaning fair or adequate social functioning, and the administrative law
judge 	found 	these 	opinions 	persuasive. 	(Doc. 	11-4, 	pp. 	43-44, 	68-69).
Based on this evidence, the administrative law judge determined that the Plaintiff could
tolerate occasional interactions with supervisors, coworkers, and the public and respond
appropriately 	during those 	interactions. 	This 	finding 	aligned 	with 	the 	consistent
assessments of the state-agency experts. The administrative law judge considered the
record in its entirety, including the Plaintiff’s interactions with family, daily activities,
engagements with providers, and the expert opinions, and concluded that the Plaintiff
can cooperate with others, understand and respond to social cues, reply to requests and
suggestions, and maintain social interactions free of excessive irritability or aggression
within the specified residual functional capacity limits. This determination is supported
by substantial evidence.
In summary, the administrative law judge’s mental residual functional capacity
determination is logically connected to the evidence and supported by substantial
evidence. Accordingly, remand on Claim 2 is not warranted.
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C. Degenerative Disc Disease and Obesity
Plaintiff argues that remand is required because the ALJ’s RFC failed to account
for the combined impact of his lumbar degenerative disc disease and obesity, rendering
it unsupported by substantial evidence. Specifically, Plaintiff contends that the ALJ’s
finding 	of 	these 	impairments 	as 	non-severe, 	without 	incorporating 	any 	physical
limitations related to pain, standing, or walking, overlooked their synergistic effects. This
argument lacks merit, as the ALJ’s analysis was thorough and supported by substantial
evidence.
The ALJ properly evaluated Plaintiff’s lumbar degenerative disc disease at step
two, noting imaging that revealed only mild spondylosis, mild degenerative arthrosis of
the right first MTP joint, and a small spur, with no acute abnormalities after a 2021 lifting
incident and mild degenerative changes in January 2022 imaging. (Doc. 11-2, pg. 22).
Even after February 2023 treatment for acute back pain and muscle strain from lifting a
stove, Plaintiff’s examination was largely normal, showing decreased lumbar range of
motion and spasms but intact gait, strength, and reflexes. (Doc. 11-2, pg. 24). These mild,
episodic findings support the ALJ’s non-severe determination and lack of exertional RFC
limitations.
The ALJ likewise addressed Plaintiff’s obesity, documenting a body mass index in
the thirties, which falls within the non-extreme category. (Doc. 11-2, pg. 14). Examinations
showed normal gait and posture, range of motion in all extremities, muscle strength,
muscle tone, and reflexes. (Doc. 11-2, pg. 14). Critically, the ALJ considered the potential
exacerbating effects of obesity, acknowledging that it “likely exacerbates [Plaintiff’s] pain
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levels and hampers his ability to move.” (Doc. 11-2, pgs. 14, 23). However, the ALJ
reasonably determined that the objective evidence did not demonstrate impacts on
musculoskeletal, 	respiratory, 	or 	cardiovascular 	functioning 	sufficient 	to 	impose
limitations beyond those in the RFC. (Doc. 11-2, pgs. 14, 23).
Plaintiff produced no medical opinion or other persuasive evidence suggesting
that his obesity, alone or in combination with disc disease, caused greater standing or
walking limitations than the ALJ found. The ALJ relied on the unrefuted opinions of
state-agency medical consultants, who concluded that Plaintiff’s non-extreme obesity
imposed no such restrictions. (Doc. 11-4, pgs. 39-40, 64-65). These experts reviewed the
record and found the combined impairments non-limiting. The ALJ bolstered his
assessment by relying on the persuasive opinion of the consultative examining physician
who evaluated Plaintiff in 2022, noting normal results including normal gait, full muscle
strength, ability to squat and rise normally, and no difficulty getting on and off the exam
table, with the physician imposing no functional restrictions. (Doc. 11-2, pgs. 23-24; Doc.
11-23 pgs. 17-27).
Plaintiff points to a 2023 physical therapy observation of reduced strength
following the stove-lifting incident. But the ALJ addressed this treatment, noting physical
therapy for low back pain without evidence of ongoing abnormal exam results affecting
standing or walking. (Doc. 11-2, pg. 24). State-agency physician Dr. Bilinsky similarly
found that Plaintiff’s conditions would not cause significant restrictions in basic work-
related functioning. (Doc. 11-4, pgs. 64-65). Moreover, Plaintiff did not testify that obesity
affected his functioning, and as discussed in the analysis of Claim 1, the ALJ reasonably
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discounted his subjective complaints as inconsistent with the objective record.
For these reasons, remand is not warranted as to Claim 3.
VI. 	Conclusion
For these reasons, the Complaint (Doc. 1) filed by Plaintiff Ronald E. D.
is DENIED, and the final decision of the Commissioner of Social Security denying his
application 	for 	Disability 	Insurance 	Benefits 	and 	Supplemental 	Security 	Income
is AFFIRMED. This action is DISMISSED with prejudice, and the Clerk of Court
is DIRECTED to enter judgment in favor of Defendant Commissioner of Social Security.
SO ORDERED.
Dated: March 16, 2026
______________________________
DAVID W. DUGAN
United States District Judge
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