Sartini, Jeffrey v. Kijakazi, Kilolo, 3:22-cv-00067-slc

Plaintiff Jeffrey Sartini applied for disability insurance benefits alleging disabling lumbar spine problems after a 2014 injury and two lumbar surgeries in 2017; insured period ended December 31, 2019.
Treating physiatrist Dr. Maya Battikha (treatment beginning July 2018) completed a questionnaire opining severe limits: sit/stand 20 minutes at a time, <2 hours total sitting/standing per 8-hour day, very limited lifting, and about one absence/month.
Two state agency consulting physicians reviewed the record and found Sartini capable of light work (about 6 hours sit/stand per day) with postural limits.
At a 2021 hearing, vocational expert testified that sedentary jobs (Sartini’s past work) were compatible with a sit/stand change once per hour for 5 minutes, but not with changes every 20 minutes.
ALJ denied benefits, adopting an RFC for sedentary work with postural limits and a sit/stand option of once per hour for five minutes; he found Dr. Battikha’s opinion unpersuasive due to conservative treatment and generally normal exam findings, and found state consultants only somewhat persuasive.
The district court affirmed, holding the ALJ’s evaluation of medical opinions and the RFC were supported by substantial evidence and complied with 20 C.F.R. § 404.1520c.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly evaluated medical opinions under 20 C.F.R. § 404.1520c	ALJ wrongly discounted treating Dr. Battikha and failed to appropriately account for a 2018 MRI and treating relationship	ALJ reasonably assessed supportability and consistency; MRI did not mandate crediting the restrictive opinion; ALJ need not defer to treating source under the new rule	Court: ALJ adequately explained supportability/consistency bases; rejection of Dr. Battikha was supported by conservative treatment and mostly normal exams, so affirmed
Whether ALJ adequately explained RFC (sedentary work + sit/stand once/hour 5 min)	RFC unsupported because ALJ didn’t tie sit/stand frequency and sedentary finding to specific evidence; treating opinion would require more restrictive limits	ALJ permissibly synthesized record (state opinions, exams, activities) and plaintiff bore burden to identify evidence requiring tighter limits; ALJ partially credited subjective complaints already	Court: RFC supported by substantial evidence; plaintiff failed to identify objective evidence that would justify greater restrictions, so affirmed

Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (standard of "substantial evidence" review)
Deborah M. v. Saul, 994 F.3d 785 (7th Cir. 2021) (court will not reweigh evidence or substitute its judgment for the Commissioner)
Burmester v. Berryhill, 920 F.3d 507 (7th Cir. 2019) (same limits on district court review of ALJ factfinding)
Grotts v. Kijakazi, 27 F.4th 1273 (7th Cir. 2022) (subjective statements about symptoms require objective support)
Moon v. Colvin, 763 F.3d 718 (7th Cir. 2014) (ALJ must build a "logical bridge" linking evidence to conclusion)
Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345 (7th Cir. 2005) (ALJ must explain analysis with sufficient detail for meaningful review)
Karr v. Saul, 989 F.3d 508 (7th Cir. 2021) (plaintiff bears burden to identify objective evidence corroborating greater limitations)
Stage v. Colvin, 812 F.3d 1121 (7th Cir. 2016) (ALJ may not improperly interpret raw medical data beyond lay understanding)
Schmidt v. Astrue, 496 F.3d 833 (7th Cir. 2007) (ALJ need not adopt any single medical opinion verbatim to craft RFC)
Loveless v. Colvin, 810 F.3d 502 (7th Cir. 2016) (claimant must identify medical evidence justifying extra restrictions)
Palmer v. Saul, [citation="779 F. App'x 394"] (7th Cir. 2019) (ALJ’s more restrictive RFC than non-examining opinions can render any error harmless)
Sosh v. Saul, [citation="818 F. App'x 542"] (7th Cir. 2020) (claimant not entitled to remand absent medical evidence justifying additional restrictions)