Steuernagel v. Kijakazi, 2:22-cv-00593

Robert J. Steuernagel applied for DIB and SSI (Oct. 24, 2019; Apr. 24, 2020) alleging disability since Dec. 29, 1990; ALJ hearings held Nov. 2020, Mar. 2021, and Jul. 2021; ALJ denied benefits and Appeals Council denied review.
ALJ found severe impairments: neurodevelopmental disorder/borderline intellectual functioning, anxiety disorder, and depressive disorder, but concluded Steuernagel retained RFC for all exertional levels with nonexertional limits (simple, routine tasks; no complex communications; low stress; only occasional decision-making and changes).
ALJ relied on clinical observations of adequate comportment (interactive, coherent, task oriented) and on claimant’s reported daily activities (cooking, laundry, cleaning, driving, attending sporting events, caring for an autistic nephew).
Claimant presented testimony from retained expert Dr. Daniel Goeckner (who never examined Steuernagel) and psychological testing/treatment records from treating psychologist Dr. Sheila Gissible.
Dr. Gissible’s testing reported poor effort and recommended vocational rehab; on a check-box form she opined marked workplace limitations and poor prognosis for competitive employment.
District court affirmed ALJ: found no bias in the hearing, and concluded the ALJ reasonably discounted both Dr. Goeckner’s and Dr. Gissible’s opinions as unpersuasive or unsupported.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ bias at hearing	ALJ’s questioning and management of expert testimony showed partiality and denied impartial hearing	ALJ was presumed impartial; his questioning sought clarity and focused testimony, not antagonism	Court: No bias; ALJ’s conduct did not show deep‑seated antagonism and was within courtroom management
Evaluation of retained expert (Dr. Goeckner)	ALJ improperly discounted expert hired by claimant; opinion should not be dismissed because retained to support claim	ALJ reasonably found opinion unpersuasive because expert didn’t examine claimant, misstated/mischaracterized record, and opined inconsistently with claimant’s reported functioning	Court: ALJ gave minimally articulated, reasonable reasons under 20 C.F.R. §404.1520c; no remand required
Evaluation of treating psychologist (Dr. Gissible)	ALJ erred in discounting treating psychologist’s marked limitations	ALJ permissibly discounted check‑box opinion for lack of explanation, no onset date, inconsistency with earlier notes (recommendation for vocational rehab), and claimant’s activities	Court: ALJ reasonably discounted Gissible’s extreme limitations; RFC determination affirmed

Jelinek v. Astrue, 662 F.3d 805 (7th Cir. 2011) (standard for affirming Commissioner where correct law and substantial evidence support ALJ)
Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (definition and low threshold of substantial evidence)
Pepper v. Colvin, 712 F.3d 351 (7th Cir. 2013) (ALJ must build a logical bridge but need not address every piece of evidence)
Stepp v. Colvin, 795 F.3d 711 (7th Cir. 2015) (deference to ALJ’s evaluation of medical opinions unless patently erroneous)
Elder v. Astrue, 529 F.3d 408 (7th Cir. 2008) (lax standard for ALJ’s minimal articulation when discounting physician opinion)
Liteky v. United States, 510 U.S. 540 (1994) (bias requires deep‑seated and unequivocal antagonism)
Reinaas v. Saul, 953 F.3d 461 (7th Cir. 2020) (solicited medical opinion in support of claim not automatically discounted)
Steele v. Barnhart, 290 F.3d 936 (7th Cir. 2002) (review limited to ALJ’s articulated rationales)