Sager v. O'Malley, 1:23-cv-00160

Plaintiff Kalonda Sager sought judicial review of the Social Security Administration’s denial of her disability insurance and SSI claims, alleging disability due to lupus, Sjögren’s syndrome, fibromyalgia, obesity, and hypothyroidism.
Sager filed her applications in June 2019, alleging disability beginning November 15, 2019.
Her claims were denied at the initial level and after a hearing before an Administrative Law Judge (ALJ) in February 2023.
The Appeals Council denied review, making the ALJ's decision the final agency action.
Sager challenged the ALJ’s findings, arguing her conditions met specific medical listings and that her residual functional capacity (RFC) determination was not supported by substantial evidence.
The District Court reviewed whether the Commissioner’s decision was supported by substantial evidence as required by law.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Did Sager’s impairments meet/equal Listings	Sager met requirements for Listings 14.02 & 14.10; ALJ erred	ALJ correctly found insufficient evidence to meet	Plaintiff did not meet the criteria;
14.02/14.10 (lupus/Sjögren’s)?	by not finding her lupus/Sjögren’s disabling	all criteria; symptoms not present at severity	decision deferred to ALJ’s findings
		or frequency required by listings
Was the RFC determination flawed?	RFC not supported; ALJ mis-summarized/ignored evidence	ALJ considered record, credible complaints,	Substantial evidence supported RFC;
	and relied on improper inferences about her treatment	and consistent conservative treatment	no error by ALJ
	regimen	regimen
Did ALJ improperly consider conservative	ALJ erred by speculating her treatment should have changed	Conservative management and improvement	Considering conservative treatment was
treatment as evidence against disability?	if symptoms were severe	undermine claim of disabling symptoms	appropriate, no error
Did ALJ fail to develop the record?	ALJ should have sought more medical input/opinions	Record sufficient as is; no unfairness or	No duty to further develop record given
		prejudice; plaintiff did not meet her burden	sufficiency of evidence

Richardson v. Perales, 402 U.S. 389 (1971) (defining “substantial evidence” as the basis for affirming agency decisions)
Bowen v. Yuckert, 482 U.S. 137 (1987) (affirming the five-step disability evaluation process)
Sullivan v. Zebley, 493 U.S. 521 (1990) (listing-level impairments create a presumption of disability only if all criteria are met)
Martise v. Astrue, 641 F.3d 909 (8th Cir. 2011) (residual functional capacity assessed at step four; substantial evidence standard)