Charlotte R. Martin v. Social Security Administration, Commissioner

Martin · United States District Court for the Eastern District of Arkansas, Central Division · February 5, 2026 · No. 4:25-CV-00596-KGB-ERE

Summary

This Recommended Disposition addresses Charlotte R. Martin’s appeal from the Commissioner of Social Security’s denial of disability benefits. The magistrate judge recommends affirming the decision, concluding that the ALJ properly evaluated the record, the severity of Martin’s impairments, her subjective complaints, her residual functional capacity, and her ability to perform past relevant work. The disposition was dated February 5, 2026.

Holdings

  1. The ALJ did not err by declining to order a consultative examination or obtain additional medical evidence because the existing record provided a sufficient basis for an informed decision.
  2. The ALJ did not err in finding Martin's anxiety and depression non-severe because the impairments had no more than a minimal effect on her ability to perform basic work activities.
  3. The ALJ properly evaluated Martin's subjective complaints because the decision considered the objective medical evidence, pain, treatment, work history, and daily activities, and reasonably found her allegations inconsistent with the record as a whole.
  4. The ALJ's sedentary RFC with additional postural restrictions was supported by the medical evidence and included the limitations that the ALJ found credible.
  5. Substantial evidence supported the ALJ's finding that Martin could perform her past relevant work as a customer order clerk, both as actually and generally performed.

Questions Presented

  1. Whether the ALJ failed to fully develop the administrative record by not ordering a consultative examination or contacting Martin's medical providers.
  2. Whether the ALJ erred in finding Martin's anxiety and depression non-severe at step two.
  3. Whether the ALJ improperly evaluated Martin's subjective complaints of pain and other symptoms.
  4. Whether the ALJ's residual functional capacity finding failed to include all supported limitations.
  5. Whether substantial evidence supported the step-four finding that Martin could perform her past relevant work as a customer order clerk.

Disposition

affirmed

Cases Cited (20)

  • 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 (8th Cir. 2015)(followed)
  • Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997)(followed)
  • McCoy v. Astrue, 648 F.3d 605, 612 (8th Cir. 2011)(followed)
  • Naber v. Shalala, 22 F.3d 186, 189 (8th Cir. 1994)(followed)
  • Adamczyk v. Saul, 817 F. App'x 287, 290 (8th Cir. 2020)(followed)
  • Milam v. Colvin, 794 F.3d 978, 985 (8th Cir. 2015)(followed)
  • Harvey v. Colvin, 839 F.3d 714 (8th Cir. 2016)(followed)

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