Tammy Sloan v. Andrew Saul, 933 F.3d 946

Tammy Sloan applied for Social Security Disability Insurance and SSI, claiming disability beginning March 28, 2014; the ALJ and Appeals Council denied benefits and the district court affirmed.
Sloan had longstanding back injury/degenerative spine problems and multiple severe impairments (migraines, lumbar/cervical degenerative disc disease, knee DJD, obesity, diabetes, bilateral carpal tunnel, vertigo).
The ALJ found Sloan capable of sedentary work with limitations (no ladders/ropes/scaffolds; only occasional ramps/stairs/stoop/crouch/kneel/crawl; frequent bilateral handling; avoid extremes, vibrations, irritants, hazards).
Sloan’s most recent employer was Sam’s Club (1998–March 2014) where she performed a mix of tasks as a phone attendant: receptionist-type duties (routing calls, checking orders) and occasional floor/stock retrieval that could require lifting ~25 lbs.
A vocational expert testified Sloan’s job appeared to include duties of both a DOT-listed receptionist and stores laborer (a possible composite job), but could be performed as a receptionist; the ALJ credited that testimony and found Sloan could perform past relevant work as a receptionist.
On appeal Sloan argued she could not perform her past work because it was a composite job and she could not perform the more strenuous elements; the Eighth Circuit affirmed, finding substantial evidence supported the ALJ’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sloan’s prior job was a composite job such that the ALJ must assess her ability to perform it as actually performed rather than as generally performed	Sloan: her job combined significant elements of receptionist and stores laborer, so it was a composite job and she cannot do the more strenuous elements	Commissioner: Sloan’s primary duties matched the DOT receptionist description; occasional heavier tasks do not convert the job into a composite job	Held for Commissioner: job matched DOT receptionist duties; not a composite job, so comparing RFC to the receptionist (as generally performed) was proper
Whether Sloan’s receptionist duties constituted "past relevant work" (substantial gainful activity)	Sloan: she did receptionist tasks only part of the time, so they may not be substantial gainful activity	Commissioner: she was paid and performed significant mental/physical duties predominately as a receptionist	Held for Commissioner: substantial evidence that receptionist duties were substantial gainful activity
Whether the ALJ’s explanation was deficient and required remand	Sloan: ALJ failed to address the composite-job testimony and provided inadequate explanation	Commissioner: ALJ cited credible vocational-expert testimony and the record permits meaningful review; any writing deficiencies are harmless	Held for Commissioner: explanation sufficient for review; deficiency, if any, had no practical effect

Chismarich v. Berryhill, 888 F.3d 978 (8th Cir. 2018) (standard for substantial evidence review)
Steed v. Astrue, 524 F.3d 872 (8th Cir. 2008) (claimant bears burden at step four to show inability to perform past relevant work)
Comstock v. Chater, 91 F.3d 1143 (8th Cir. 1996) (definition of substantial gainful activity for past work)
Carmickle v. Comm’r, 533 F.3d 1155 (9th Cir. 2008) (error in using the least demanding aspects of claimant’s job to classify past work)
Senne v. Apfel, 198 F.3d 1065 (8th Cir. 1999) (harmlessness of opinion-writing deficiencies when they do not affect the outcome)