Karen S. Q., a 59-year-old former commercial cleaner and dispatcher, sought judicial review of the Social Security Administration's denial of her disability insurance benefits application, claiming disability since March 2020 due to spinal stenosis, osteoarthritis, and diabetes. Her attorney argued that Administrative Law Judge Randolph Alden failed to properly evaluate evidence showing she could not sit for the extended periods required for sedentary work, which typically demands six hours of sitting per eight-hour workday.
Judge Kanne rejected the plaintiff's arguments, finding that the ALJ had sufficiently addressed her sitting limitations in his analysis. "The ALJ acknowledged Plaintiff's reports of back and hip pain and that such pain was aggravated by sitting and driving, among other activities," Kanne wrote, noting the ALJ also considered that "conservative treatment relieved the pain." The judge emphasized that the ALJ specifically included language in the residual functional capacity assessment allowing the plaintiff to "sit, with normal breaks, for a total of 6 hours per 8-hour workday."
Judge Kanne distinguished the case from a Northern District of Illinois decision, Cari B. v. Bisignano, which the plaintiff's counsel cited as having "extremely similar" circumstances. "Unlike the string of cases cited in Cari B., where the ALJs failed to specifically address the claimants' ability to sit, here the ALJ discussed—albeit perhaps briefly—parts of the record that pertained to Plaintiff's sitting ability," Kanne wrote.
The plaintiff had applied for benefits on June 9, 2022, alleging disability beginning March 20, 2020. After initial denials, she received a telephonic hearing before ALJ Alden on January 25, 2024, where she was represented by counsel and vocational expert Sarah Whitten testified. The ALJ concluded she was not disabled as defined under the Social Security Act through February 22, 2024, finding she could perform her past relevant work as a dispatcher.
Plaintiff's counsel had argued that the ALJ ignored multiple medical records documenting her sitting difficulties and failed to provide adequate analysis of these limitations. The attorney pointed to numerous record citations showing reports of sitting problems, contending the ALJ's "sparse acknowledgment" of this evidence was insufficient to support a finding that the plaintiff could perform sedentary work.
The court noted that the ALJ specifically considered and rejected consultative examiner Dr. Steven Fitts's opinion that the plaintiff could not sit, stand, walk, lift, carry, or handle objects on either a frequent or occasional basis. Judge Kanne wrote that the ALJ found this opinion "not supported by the examination conducted," noting that "[t]he musculoskeletal exam was also normal, with no tenderness, crepitus, or sensory deficit and she was able to get on and off the exam table without difficulty."
Concluding his analysis, Judge Kanne emphasized that while the ALJ's discussion "perhaps was not perfect," it was "far from completely lacking." He noted that "[t]he ALJ need not address every piece of evidence in his decision, but he cannot ignore a line of evidence that undermines the conclusions he made, and he must trace the path of his reasoning and connect the evidence to his findings and conclusions." The court found the ALJ's consideration of the record was sufficient and supported by substantial evidence.