Mary Smith-Jones v. Social Security Administration, Commissioner

Smith-Jones · United States District Court for the Eastern District of Arkansas, Central Division · November 24, 2025 · No. 4:25-CV-00304-LPR-ERE

Summary

The document is a Recommended Disposition in a Social Security disability appeal before the United States District Court for the Eastern District of Arkansas. The magistrate judge recommends affirming the Commissioner’s denial of benefits, concluding that the ALJ properly assessed the claimant’s residual functional capacity, evaluated the medical opinions and subjective complaints, developed the record, and determined that she could perform her past relevant work. The disposition was dated November 24, 2025.

Holdings

  1. The ALJ did not err by describing Smith-Jones's capacity as sedentary work with specified additional limitations rather than mechanically listing every function associated with sedentary work.
  2. The ALJ properly evaluated the consultative and state-agency medical opinions and was not required to adopt any opinion line by line.
  3. The ALJ was not required to recontact Dr. Eberle or order additional testing because the existing record was sufficient to decide the disability claim.
  4. The ALJ properly evaluated Smith-Jones's subjective complaints, and substantial evidence supported the conclusion that her allegations of debilitating pain were inconsistent with the record.
  5. The ALJ properly determined that Smith-Jones could perform her past relevant work as a coordinator in skill training and as a secretary as those jobs are generally performed in the national economy.

Questions Presented

  1. Whether the ALJ adequately assessed Smith-Jones's residual functional capacity without mechanically specifying every function of sedentary work.
  2. Whether the ALJ properly evaluated the medical opinion evidence.
  3. Whether the ALJ failed to fully and fairly develop the administrative record by not recontacting the consultative examiner or ordering additional testing.
  4. Whether the ALJ properly evaluated Smith-Jones's subjective complaints.
  5. Whether substantial evidence supported the ALJ's step-four finding that Smith-Jones could perform her past relevant work.

Disposition

affirmed

Cases Cited (22)

  • Brown v. Colvin, 825 F.3d 936, 939 (8th Cir. 2016)(followed)
  • Halverson v. Astrue, 600 F.3d 922, 929 (8th Cir. 2010)(followed)
  • Slusser v. Astrue, 557 F.3d 923, 925 (8th Cir. 2009)(followed)
  • Milam v. Colvin, 794 F.3d 978, 983, 985 (8th Cir. 2015)(followed)
  • Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997)(followed)
  • Nash v. Commissioner of Social Security Administration, 907 F.3d 1086, 1090-91 (8th Cir. 2018)(followed)
  • McCoy v. Astrue, 648 F.3d 605, 615 (8th Cir. 2011)(followed)
  • Menter v. Kijakazi, No. 6:20-CV-003198-DGK, 2022 WL 188146, at *2 (W.D. Mo. Jan. 20, 2022)(followed)
  • Duvall v. Bisignano, No. 4:25-cv-00120 KGB-PSH, 2025 WL 1812626, n.6 (E.D. Ark. July 1, 2025)(followed)
  • Locher v. Sullivan, 968 F.2d 725, 728 (8th Cir. 1992)(followed)

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