Alexis Rogers on behalf of KCF v. Martin O’Malley, Commissioner, Social Security Administration

Rogers v. O’Malley · United States District Court for the Eastern District of Arkansas, Central Division · December 4, 2025 · No. No. 4:25-cv-00663-JM-JJV

Summary

This proposed findings and recommended disposition addresses a pro se appeal challenging the denial of supplemental security income benefits to a minor child. The magistrate judge concluded that the Administrative Law Judge’s determination that the child’s impairments did not meet, medically equal, or functionally equal a listed impairment was supported by substantial evidence. The document recommends affirming the Commissioner’s decision and dismissing the complaint with prejudice.

Holdings

  1. The ALJ's determination that KCF did not have marked limitations in two functional domains or an extreme limitation in one domain was supported by substantial evidence and was not based on legal error.
  2. The court could not consider evidence obtained after the administrative proceedings that was not part of the record before the Commissioner.
  3. A sentence-six remand was not warranted because Plaintiff did not show that the later-obtained condition existed before May 29, 2024.

Questions Presented

  1. Whether substantial evidence supported the ALJ's determination that KCF's impairments did not functionally equal a listed impairment.
  2. Whether the ALJ adequately considered KCF's combined impairments and educational evidence.
  3. Whether evidence of an autism diagnosis obtained after the ALJ's decision could be considered on judicial review or warranted a sentence-six remand.

Disposition

affirmed

Cases Cited (11)

  • Prosch v. Apfel, 201 F.3d 1010, 1012 (8th Cir. 2000)(followed)
  • Richardson v. Perales, 402 U.S. 389, 390, 401 (1971)(followed)
  • Johnson v. Chater, 87 F.3d 1015, 1017 (8th Cir. 1996)(followed)
  • Ostronski v. Chater, 94 F.3d 413, 416 (8th Cir. 1996)(followed)
  • Ingram v. Chater, 107 F.3d 598, 601 (8th Cir. 1997)(followed)
  • Sullivan v. Zebley, 493 U.S. 521, 530 (1990)(followed)
  • Marciniak v. Shalala, 49 F.3d 1350, 1351 (8th Cir. 1995)(followed)
  • Jones v. Callahan, 122 F.3d 1148, 1154 (8th Cir. 1997)(followed)
  • Mapes v. Chater, 82 F.3d 259, 262 (8th Cir. 1996)(followed)
  • Pratt v. Sullivan, 956 F.2d 830, 833 (8th Cir. 1992)(followed)

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Cited In (0)

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