Phyllis Y. BLACK, Appellant, v. Kenneth S. APFEL, Comm'r, Soc. Sec. Admin., Appellee, 143 F.3d 383 (8th Cir. 1998). · Go Syfert
Phyllis Y. BLACK, Appellant, v. Kenneth S. APFEL, Comm'r, Soc. Sec. Admin., Appellee, 143 F.3d 383 (8th Cir. 1998). Cases Citing This Book View Copy Cite
Quick Summary

An administrative law judge is not required to discuss every piece of evidence submitted, and failure to cite specific evidence does not mean that evidence was not considered.

An appellant seeking social security disability benefits challenged an administrative law judge's decision, arguing the judge failed to discuss a treating physician's opinion and improperly discredited her subjective pain complaints. The court held that while an administrative law judge must develop the record fully and fairly, they are not required to discuss every piece of evidence submitted. Furthermore, a failure to cite specific evidence does not necessarily indicate that such evidence was not considered. Because the administrative law judge's decision was supported by substantial evidence and properly applied relevant factors to assess credibility, the court affirmed the denial of benefits.

679 citation events (652 in the last 25 years) across 41 distinct courts.
Treatment trajectory · 1998 → 2026 · click a year to view as-of
1998 2012 2026
Cited for
At page 386 ALJ's failure to cite evidence does not mean it was not considered444 citing casesAlthough required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted. An ALJ's failure to cite specific evidence does not indicate that such evidence was not considered.107 citing courts put it this way · 257 listed here
  • Leeper, No. 2:25-cv-00305 (E.D. Wash. Feb. 25, 2026).
    (An ALJ’s failure to cite 18 specific evidence does not indicate that such evidence was not 19 considered[.])
  • Hicks, No. 4:24-cv-01453 (E.D. Mo. Jan. 6, 2026).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted. An ALJ's failure to cite specific evidence does not indicate that such evidence was not con…)
  • Rand v. Dudek, No. 2:24-cv-00379 (E.D. Wash. Apr. 9, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Lawton v. Dudek, No. 2:24-cv-00343 (E.D. Wash. Apr. 9, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Cardenas v. Dudek, No. 1:24-cv-03177 (E.D. Wash. Apr. 9, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Krenzelok v. Dudek, No. 0:23-cv-03883 (D. Minn. Mar. 26, 2025).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted.)
  • Burke v. Comm'r of the Soc. Sec. Admin., No. 5:23-cv-06635 (D.S.C. Mar. 25, 2025).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted.)
  • Donges v. Dudek, No. 2:24-cv-00266 (E.D. Wash. Mar. 17, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Parker v. O'Malley, No. 1:24-cv-00008 (E.D. Mo. Mar. 4, 2025).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted. An 12 ALJ's failure to cite specific evidence does not indicate that such evidence was not…)
  • Brandt v. Colvin, No. 2:24-cv-04089 (W.D. Mo. Mar. 3, 2025).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted.)
Show 247 more citing cases
  • Bartley v. Duduk, No. 2:24-cv-00303 (E.D. Wash. Feb. 26, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Ferring v. Dudek, No. 4:24-cv-05104 (E.D. Wash. Feb. 26, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Stueckle v. Dudek, No. 4:24-cv-05074 (E.D. Wash. Feb. 26, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Pakootas v. Dudek, No. 2:24-cv-00348 (E.D. Wash. Feb. 26, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Winegarner v. Colvin, No. 4:24-cv-00187 (W.D. Mo. Feb. 20, 2025).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted.)
  • Torres v. King, No. 2:24-cv-00313 (E.D. Wash. Feb. 12, 2025). 2 cites
    (An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.])
  • Forbes v. King, No. 4:24-cv-05098 (E.D. Wash. Feb. 12, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Roll v. King, No. 1:24-cv-03139 (E.D. Wash. Jan. 29, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Abstance v. Comm'r of the Soc. Sec. Admin., No. 5:24-cv-00687 (D.S.C. Jan. 24, 2025).
    (Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted.)
  • Barrett v. Colvin, No. 4:24-cv-05073 (E.D. Wash. Jan. 9, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Powell v. Colvin, No. 4:24-cv-05096 (E.D. Wash. Jan. 9, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Benson v. Colvin, No. 4:24-cv-05075 (E.D. Wash. Jan. 9, 2025).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Schultz v. Colvin, No. 2:24-cv-00191 (E.D. Wash. Dec. 16, 2024).
    (An ALJ’s failure to cite specific evidence does 20 not indicate that such evidence was not considered[.])
  • Balzer v. Colvin, No. 1:24-cv-03098 (E.D. Wash. Dec. 16, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Bichler v. Colvin, No. 2:24-cv-00164 (E.D. Wash. Dec. 12, 2024).
    (An ALJ’s failure to cite specific evidence does 21 not indicate that such evidence was not considered[.])
  • Jackson v. Colvin, No. 1:24-cv-03086 (E.D. Wash. Dec. 10, 2024).
    (An ALJ’s failure to cite specific evidence does 20 not indicate that such evidence was not considered[.])
  • Stark v. Colvin, No. 2:24-cv-00201 (E.D. Wash. Dec. 10, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Grundy v. O'Malley, No. 1:24-cv-03095 (E.D. Wash. Nov. 26, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Fowler v. O'Malley, No. 4:24-cv-05061 (E.D. Wash. Oct. 30, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Rios v. O'Malley, No. 2:24-cv-00172 (E.D. Wash. Oct. 30, 2024).
    (An ALJ’s failure to cite specific evidence does 20 not indicate that such evidence was not considered[.])
  • Linse v. O'Malley, No. 1:24-cv-03076 (E.D. Wash. Oct. 28, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Bray v. O'Malley, No. 2:24-cv-00182 (E.D. Wash. Oct. 9, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Gessel v. O'Malley, No. 4:24-cv-05038 (E.D. Wash. Sept. 25, 2024).
    (An ALJ’s failure to cite specific evidence does 21 not indicate that such evidence was not considered[.])
  • Malcomb v. O'Malley, No. 1:24-cv-03070 (E.D. Wash. Sept. 24, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Marino v. O'Malley, No. 4:24-cv-05036 (E.D. Wash. Sept. 11, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Larsen v. O'Malley, No. 4:24-cv-05035 (E.D. Wash. Sept. 4, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • McClinton v. O'Malley, No. 2:24-cv-00110 (E.D. Wash. Sept. 4, 2024).
    (An ALJ’s failure to cite specific evidence does 21 not indicate that such evidence was not considered[.])
  • Salinas-Gonzalez v. O'Malley, No. 1:24-cv-03034 (E.D. Wash. Sept. 4, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Stevenson v. O'Malley, No. 1:24-cv-03039 (E.D. Wash. Aug. 19, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Contreras v. O'Malley, No. 1:24-cv-03023 (E.D. Wash. Aug. 14, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Morefield v. O'Malley, No. 1:24-cv-03038 (E.D. Wash. Aug. 14, 2024).
    (An ALJ’s failure to cite specific evidence does 17 not indicate that such evidence was not considered[.])
  • Valladares v. O'Malley, No. 4:24-cv-05025 (E.D. Wash. Aug. 14, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Brain v. O'Malley, No. 1:24-cv-03031 (E.D. Wash. Aug. 14, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Stevens v. O'Malley, No. 1:24-cv-03005 (E.D. Wash. Aug. 14, 2024).
    (An ALJ’s failure to cite specific evidence does 18 not indicate that such evidence was not considered[.])
  • Brindamour v. O'Malley, No. 1:23-cv-03206 (E.D. Wash. July 30, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Hyde v. O'Malley, No. 1:24-cv-03018 (E.D. Wash. July 25, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Crook v. O'Malley, No. 1:23-cv-03181 (E.D. Wash. July 25, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Hamilton v. O'Malley, No. 2:23-cv-00298 (E.D. Wash. July 12, 2024).
    (An ALJ’s failure to cite specific evidence does 18 not indicate that such evidence was not considered[.])
  • Robledo v. O'Malley, No. 1:24-cv-03007 (E.D. Wash. July 1, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Hughes v. O'Malley, No. 1:23-cv-03189 (E.D. Wash. May 21, 2024).
    (An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.])
  • Gauda v. Comm'r of Soc. Sec., No. 23-594, 2024 WL 886595 (2d Cir. Mar. 1, 2024).unpublished
  • Saidian v. Kijakazi, No. 2022-0362 (D.D.C. May 14, 2024).published
  • Nolen v. Soc. Sec. Admin., No. 3:21-cv-00072 (E.D. Ark. Mar. 31, 2022).
  • Bowerman v. Soc. Sec. Admin. Comm'r, No. 5:23-cv-05050 (W.D. Ark. Mar. 31, 2024).
  • (SS) Goodeill v. Comm'r of Soc. Sec., No. 1:21-cv-00242 (E.D. Cal. Dec. 29, 2023).
  • (SS) Van Groningen v. Comm'r of Soc. Sec., No. 1:21-cv-01377 (E.D. Cal. Apr. 23, 2024).
  • Rivera v. Kijakazi, No. 3:22-cv-00784 (D. Conn. Sept. 29, 2023).
  • Babcock v. Kijakazi, No. 1:21-cv-01110 (D. Del. Oct. 20, 2022).
  • Brown v. Kijakazi, No. 1:22-cv-01022 (D. Del. Mar. 20, 2023).
  • Margis v. Kijakazi, No. 1:22-cv-00463 (D. Del. Mar. 30, 2023).
  • Yamasaki v. Kijakazi, No. 1:21-cv-00117 (D. Haw. May 31, 2022).
  • Dudrey v. Comm'r of Soc. Sec., No. 1:20-cv-00079 (N.D. Iowa Mar. 30, 2022).
  • Sidney v. Comm'r of Soc. Sec., No. 5:21-cv-04033 (N.D. Iowa July 28, 2022).
  • Bauer v. Comm'r of Soc. Sec., No. 6:21-cv-02008 (N.D. Iowa Sept. 30, 2022).
  • Clayton v. Comm'r of Soc. Sec., No. 5:21-cv-04008 (N.D. Iowa Sept. 30, 2022).
  • Widener v. Comm'r of Soc. Sec., No. 2:22-cv-01028 (N.D. Iowa Mar. 6, 2024).
  • Christensen v. Comm'r of Soc. Sec., No. 5:22-cv-04036 (N.D. Iowa Oct. 30, 2023).
  • Houlihan v. Kijakazi, No. 0:20-cv-02061 (D. Minn. Mar. 30, 2022).
  • Malchow v. Kijakazi, No. 0:21-cv-00019 (D. Minn. June 21, 2022).
  • Mitchell v. Kijakazi, No. 0:21-cv-00633 (D. Minn. June 21, 2022).
  • Rewitzer v. Kijakazi, No. 0:20-cv-02593 (D. Minn. July 8, 2022).
  • Rahim v. Kijakazi, No. 0:21-cv-00078 (D. Minn. July 29, 2022).
  • Amundson v. Kijakazi, No. 0:21-cv-01217 (D. Minn. Aug. 15, 2022).
  • Christopher v. Kijakazi, No. 0:21-cv-01612 (D. Minn. Sept. 26, 2022).
  • Greenwood v. Kijakazi, No. 0:21-cv-01834 (D. Minn. Sept. 23, 2022).
  • Dawn v. Kijakazi, No. 0:21-cv-02656 (D. Minn. Mar. 14, 2023).
  • Harrington v. Kijakazi, No. 0:22-cv-00471 (D. Minn. Mar. 15, 2023).
  • Elsenpeter v. Kijakazi, No. 0:22-cv-01011 (D. Minn. Sept. 8, 2023).
  • McKinney v. Kijakazi, No. 0:23-cv-00405 (D. Minn. Sept. 27, 2023).
  • Rojas v. O'Malley, No. 0:22-cv-02952 (D. Minn. Mar. 13, 2024).
  • Pierce v. Saul, No. 4:20-cv-01426 (E.D. Mo. Mar. 25, 2022).
  • Rivers v. Kijakazi, No. 1:21-cv-00100 (E.D. Mo. Apr. 11, 2022).
  • Kamper v. Saul, No. 4:21-cv-00107 (E.D. Mo. May 17, 2022).
  • Virant v. Saul, No. 4:20-cv-01699 (E.D. Mo. July 19, 2022).
  • Ursery v. Kijakazi, No. 4:20-cv-01781 (E.D. Mo. Sept. 14, 2022).
  • Obaid v. Kijakazi, No. 4:20-cv-01859 (E.D. Mo. Sept. 12, 2022).
  • Watson v. Saul, No. 4:20-cv-01144 (E.D. Mo. Feb. 8, 2023).
  • Kribble v. Kijakazi, 663 F. Supp. 3d 1016 (E.D. Mo. 2023).published
  • Sumner v. Kijakazi, No. 4:22-cv-00331 (E.D. Mo. Mar. 31, 2023).
  • Whalen v. Kijakazi, No. 4:22-cv-00431 (E.D. Mo. Sept. 5, 2023).
  • Bedore v. Kijakazi, No. 4:22-cv-00567, 2023 WL 6064854 (E.D. Mo. Sept. 18, 2023).
  • Spencer v. O'Malley, No. 4:23-cv-00306 (E.D. Mo. Feb. 12, 2024).
  • Rudloff v. O'Malley, No. 4:23-cv-00416, 2024 WL 1140930 (E.D. Mo. Mar. 15, 2024).
  • Fisher v. O'Malley, No. 4:23-cv-00055 (E.D. Mo. Mar. 29, 2024).
  • Bingham v. Kijakazi, No. 3:21-cv-05039 (W.D. Mo. June 9, 2022).
  • Thompson v. Kijakazi, No. 3:22-cv-05078 (W.D. Mo. June 20, 2023).
  • Bair v. Kijakazi, No. 8:23-cv-00061 (D. Neb. Dec. 8, 2023).
  • McFadden v. Comm'r of Soc. Sec., No. 8:23-cv-00090 (D. Neb. Mar. 11, 2024).
  • Robinson v. Soc. Sec., No. 2:21-cv-00721 (D. Nev. July 15, 2022).
  • Volk v. Kijakazi, No. 2:20-cv-00738 (D. Nev. July 25, 2022).
  • Floyd v. Comm'r of Soc. Sec., No. 5:20-cv-01488 (N.D.N.Y. June 7, 2022).
  • Allen v. Comm'r of Soc. Sec., No. 6:21-cv-00185 (N.D.N.Y. Sept. 12, 2022).
  • Turner v. Comm'r of Soc. Sec., No. 1:20-cv-00253 (W.D.N.Y. Nov. 9, 2022).
  • Gibson v. Comm'r Soc. Sec. Admin., No. 3:20-cv-01002 (D. Or. July 12, 2022).
  • Estrada v. Comm'r Soc. Sec. Admin., No. 3:22-cv-00745 (D. Or. Oct. 19, 2023).
  • Pratt v. Saul, No. 2:20-cv-06176 (E.D. Pa. July 12, 2023).
  • Pratt v. Saul, No. 2:20-cv-06141 (E.D. Pa. July 12, 2023).
  • Coe v. Comm'r of the Soc. Sec. Admin., No. 5:22-cv-00226 (D.S.C. Jan. 27, 2023).
  • Abstance v. Comm'r of the Soc. Sec. Admin., No. 5:21-cv-04104 (D.S.C. Feb. 9, 2023).
  • B.Y.R.D. v. Comm'r of the Soc. Sec. Admin., No. 5:22-cv-00336 (D.S.C. Apr. 20, 2023).
  • Brown v. Comm'r of the Soc. Sec. Admin., No. 5:22-cv-02321 (D.S.C. Aug. 24, 2023).
  • Williams v. Kijakazi, No. 5:21-cv-05074 (D.S.D. Mar. 27, 2023).
  • Hannah v. Comm'r of Soc. Sec., No. 3:23-cv-03008 (N.D. Iowa Sept. 13, 2024).
  • Thao v. O'Malley, No. 0:24-cv-01554 (D. Minn. Oct. 11, 2024).
  • Northcutt v. O'Malley, No. 4:24-cv-00200 (E.D. Mo. Sept. 6, 2024).
  • Carey v. O'Malley, No. 4:23-cv-00860, 2024 WL 4238691 (E.D. Mo. Sept. 19, 2024).
  • Griffith v. Kijakazi, No. 1:23-cv-00035 (E.D. Mo. Sept. 24, 2024).
  • Masters v. Kijakazi, No. 4:20-cv-05179 (E.D. Wash. Mar. 22, 2022).
  • Smith v. Kijakazi, No. 4:21-cv-05121 (E.D. Wash. June 27, 2022).
  • Larimer v. O'Malley, No. 1:22-cv-03005 (E.D. Wash. Dec. 29, 2022).
  • Lebert v. Kijakazi, No. 4:21-cv-05155 (E.D. Wash. Mar. 1, 2023).
  • Moore v. Kijakazi, No. 4:22-cv-05027 (E.D. Wash. Mar. 6, 2023).
  • Runions v. Kijakazi, No. 2:21-cv-00340 (E.D. Wash. Mar. 17, 2023).
  • Olson v. Kijakazi, No. 2:22-cv-00104 (E.D. Wash. Mar. 29, 2023).
  • Davis v. Kijakazi, No. 1:22-cv-03047 (E.D. Wash. Mar. 29, 2023).
  • Schoen v. Kijakazi, No. 4:22-cv-05171 (E.D. Wash. Sept. 27, 2023).
  • Otte v. Kijakazi, No. 4:23-cv-05033 (E.D. Wash. Sept. 28, 2023).
  • Harlow v. O'Malley, No. 2:23-cv-00123 (E.D. Wash. Oct. 18, 2023).
  • Coulter v. O'Malley, No. 1:23-cv-03040 (E.D. Wash. Dec. 7, 2023).
  • Smith v. O'Malley, No. 2:23-cv-00191 (E.D. Wash. Dec. 7, 2023).
  • Sandberg v. O'Malley, No. 2:23-cv-00214 (E.D. Wash. Jan. 5, 2024).
  • Kamphaus v. O'Malley, No. 2:23-cv-00199 (E.D. Wash. Jan. 3, 2024).
  • Russell v. O'Malley, No. 1:23-cv-03106 (E.D. Wash. Mar. 6, 2024).
  • Frueh v. O'Malley, No. 1:23-cv-03135 (E.D. Wash. Mar. 6, 2024).
  • Grish v. O'Malley, No. 2:23-cv-00297 (E.D. Wash. Mar. 13, 2024).
  • Roeder v. O'Malley, No. 4:23-cv-05107 (E.D. Wash. Apr. 1, 2024).
  • Schill v. O'Malley, No. 2:23-cv-00302 (E.D. Wash. Apr. 9, 2024).
  • Galvez v. O'Malley, No. 1:23-cv-03143 (E.D. Wash. Apr. 10, 2024).
  • Sprinkle v. O'Malley, No. 2:23-cv-00333 (E.D. Wash. Apr. 10, 2024).
  • Beazley v. O'Malley, No. 1:23-cv-03154 (E.D. Wash. Apr. 10, 2024).
  • Perry v. O'Malley, No. 2:23-cv-00211 (E.D. Wash. Apr. 10, 2024).
  • Groth v. O'Malley, No. 2:23-cv-00350 (E.D. Wash. Apr. 19, 2024).
  • Schoessler v. O'Malley, No. 4:23-cv-05169 (E.D. Wash. Apr. 19, 2024).
  • Senior v. O'Malley, No. 4:23-cv-05152 (E.D. Wash. Apr. 22, 2024).
  • Par. v. O'Malley, No. 2:23-cv-00347 (E.D. Wash. May 8, 2024).
  • Small v. O'Malley, No. 2:23-cv-00325 (E.D. Wash. May 8, 2024).
  • Seely v. O'Malley, No. 2:24-cv-00001 (E.D. Wash. May 21, 2024).
  • Briggs v. Comm'r of Soc. Sec., No. 2:22-cv-00788 (W.D. Wash. Dec. 12, 2022).
  • Kreps v. Comm'r of Soc. Sec., No. 1:22-cv-00476 (W.D.N.Y. Nov. 12, 2024).
  • Steven Ahearn v. Carolyn Colvin, No. 23-35572, 2024 WL 5040995 (9th Cir. Dec. 9, 2024).unpublished
  • Wade v. Kijakazi, No. 4:23-cv-03240 (D. Neb. Dec. 12, 2024).
  • Clark v. O'Malley, No. 5:23-cv-01025 (N.D.N.Y. Sept. 3, 2024).
  • Flake v. Kijakazi, No. 4:23-cv-01582 (E.D. Mo. Feb. 10, 2025).
  • Whitfield v. Dudek, No. 0:24-cv-03047 (D. Minn. Feb. 25, 2025).
  • Young v. Dudek, No. 0:23-cv-03813 (D. Minn. Mar. 4, 2025).
  • Jungwirth v. Dudek, No. 0:23-cv-03052 (D. Minn. Mar. 12, 2025).
  • Robertson v. Dudek, No. 4:24-cv-00337 (E.D. Mo. Mar. 13, 2025).
  • Newton v. Kijakazi, No. 4:23-cv-01382 (E.D. Mo. Mar. 25, 2025).
  • Reyes v. Comm'r of Soc. Sec., No. 1:23-cv-01319 (W.D.N.Y. Mar. 27, 2025).
  • Simoes v. Kijakazi, No. 3:23-cv-01594 (D. Conn. Mar. 28, 2025).
  • Trevino o.b.o. KT v. Bisignano, No. 4:24-cv-05125 (E.D. Wash. June 5, 2025).
  • Wittrock v. Bisignano, No. 4:25-cv-03050 (D. Neb. Sept. 3, 2025).
  • Draeger v. Comm'r of Soc. Sec., No. 2:24-cv-01034 (N.D. Iowa Sept. 4, 2025).
  • Chambers v. O'Malley, No. 2024-2975 (D.D.C. Sept. 18, 2025).published
  • Zacheis, No. 3:24-cv-10936 (D.N.J. Oct. 14, 2025).
  • Abenicio F. C. v. Frank Bisignano, Comm'r of Soc. Sec., No. 2:24-cv-06481 (C.D. Cal. Oct. 17, 2025).
  • Whitelocke, No. 1:24-cv-00191 (W.D.N.Y. Nov. 5, 2025).
  • Pittillo, No. 4:24-cv-00504 (D. Ariz. Nov. 10, 2025).
  • Turner, No. 4:25-cv-00376 (E.D. Mo. Nov. 18, 2025).
  • Boyer, No. 4:25-cv-00394 (E.D. Mo. Nov. 19, 2025).
  • Moore, No. 4:25-cv-00417 (E.D. Ark. Nov. 17, 2025).
  • Holman, No. 2:25-cv-00610 (D. Nev. Nov. 21, 2025).
  • Preston, No. 1:24-cv-00306 (W.D.N.Y. Dec. 8, 2025).
  • Mendez, No. 4:24-cv-00811 (W.D. Mo. Dec. 30, 2025).
  • Toler, No. 4:25-cv-00150 (E.D. Mo. Jan. 6, 2026).
  • Fahrer, No. 1:24-cv-00464 (W.D.N.Y. Jan. 12, 2026).
  • Bowling, No. 1:25-cv-00064 (E.D. Mo. Feb. 10, 2026).
  • Symonds, No. 3:24-cv-03053 (N.D. Iowa Feb. 18, 2026).
  • Ray, No. 3:24-cv-05078 (W.D. Mo. Mar. 24, 2026).
  • Hiatt, No. 4:24-cv-01544 (E.D. Mo. Mar. 10, 2026).
  • Kline, No. 2:25-cv-01010 (N.D. Iowa Mar. 30, 2026).
  • Bisignano, No. 4:25-cv-00249 (E.D. Mo. Mar. 25, 2026).
  • Moore, No. 5:25-cv-05153 (W.D. Ark. May 28, 2026).
  • Culp, No. 3:25-cv-01190 (D. Conn. July 16, 2026).
  • Carlson, No. 0:25-cv-02831 (D. Minn. July 31, 2026).
  • Wadlow, No. 1:25-cv-00150 (E.D. Mo. Aug. 3, 2026).
  • Hainline, No. 2:25-cv-00068 (E.D. Mo. Aug. 10, 2026).
  • O'Dell, No. 3:25-cv-03045 (N.D. Iowa Aug. 17, 2026).
  • Martin, No. 0:25-cv-03202 (D. Minn. Aug. 31, 2026).
  • Seemiller, No. 4:25-cv-00849 (E.D. Mo. Sept. 4, 2026).
  • Harrison, No. 5:25-cv-04023 (N.D. Iowa Sept. 17, 2026).
  • Greenauer, No. 1:25-cv-00385 (W.D.N.Y. Sept. 22, 2026).
  • Whittington, No. 4:25-cv-00510 (E.D. Ark. Sept. 28, 2026).
  • Forgason v. Soc. Sec. Admin. Comm'r, No. 5:22-cv-05070 (W.D. Ark. Sept. 29, 2023).
  • Guthrie v. Soc. Sec. Admin., No. 3:23-cv-00128 (E.D. Ark. Aug. 27, 2024).
  • Becirovic v. Kijakazi, No. 3:23-cv-01062 (D. Conn. Aug. 21, 2024).
  • Morales v. Comm'r of Soc. Sec., No. 6:23-cv-06490 (W.D.N.Y. Oct. 3, 2024).
  • Petersen v. Comm'r of Soc. Sec., No. 1:23-cv-01314 (W.D.N.Y. Oct. 31, 2024).
  • Reed v. Comm'r of Soc. Sec., No. 1:22-cv-00099 (D.N.D. Nov. 26, 2024).
  • Dixon v. Dudek, No. 4:23-cv-01583 (E.D. Mo. Mar. 10, 2025).
  • Rogers v. Bisignano, No. 1:24-cv-03197 (E.D. Wash. May 19, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Kiehl v. Bisignano, No. 1:24-cv-03195 (E.D. Wash. May 28, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Hinkle v. Bisignano, No. 1:25-cv-03002 (E.D. Wash. June 5, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Flores v. Bisignano, No. 1:24-cv-03198 (E.D. Wash. June 12, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Kobernic, No. 1:25-cv-03016 (E.D. Wash. Oct. 14, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Heard, No. 1:25-cv-03019 (E.D. Wash. Oct. 14, 2025).
    “An ALJ’s failure to cite specific evidence does not 19 indicate that such evidence was not considered[.]”
  • Hopkins, No. 1:25-cv-03056 (E.D. Wash. Oct. 14, 2025).
    “An ALJ’s failure to cite specific evidence does not 19 indicate that such evidence was not considered[.]”
  • Hounshell, No. 2:25-cv-00009 (E.D. Wash. Oct. 14, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Kendall v. Bisignano, No. 2:25-cv-00007 (E.D. Wash. July 9, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Puccini v. Bisignano, No. 2:25-cv-00010 (E.D. Wash. July 9, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Banks v. Bisignano, No. 4:24-cv-05163 (E.D. Wash. July 9, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Ray v. Bisignano, No. 4:25-cv-05001 (E.D. Wash. July 9, 2025).
    “An ALJ’s failure to cite specific evidence does 15 not indicate that such evidence was not considered[.]”
  • Martinez-Escobar, No. 1:25-cv-03060 (E.D. Wash. Nov. 12, 2025).
    “An ALJ’s failure to cite specific evidence does not 19 indicate that such evidence was not considered[.]”
  • Farnsworth, No. 1:25-cv-03061 (E.D. Wash. Nov. 12, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Hansen v. Saul, No. 4:20-cv-05006 (E.D. Wash. Nov. 18, 2020).
    “An ALJ's failure to cite specific evidence does not 22 indicate that such evidence was not considered[.]”
  • LaMarsh v. Saul, No. 4:20-cv-05058 (E.D. Wash. Apr. 13, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Herrera v. Saul, No. 4:20-cv-05092 (E.D. Wash. Apr. 13, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Byrne v. Kijakazi, No. 4:20-cv-05080 (E.D. Wash. Apr. 23, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 17 such evidence was not considered[.]”
  • Day v. Saul, No. 4:20-cv-05124 (E.D. Wash. May 10, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Rydberg v. Kijakazi, No. 4:20-cv-05097 (E.D. Wash. May 13, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 22 such evidence was not considered[.]”
  • Smith v. Saul, No. 4:20-cv-05096 (E.D. Wash. June 11, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Blewett v. Kijakazi, No. 4:20-cv-05126 (E.D. Wash. June 10, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Campbell v. Kijakazi, No. 4:20-cv-05114 (E.D. Wash. June 30, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 21 such evidence was not considered[.]”
  • Kuh v. O'Malley, No. 4:20-cv-05115 (E.D. Wash. July 29, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 21 such evidence was not considered[.]”
  • Bell v. Kijakazi, No. 4:20-cv-05109 (E.D. Wash. Sept. 1, 2021).
    “An ALJ’s failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Charwood v. Kijakazi, No. 4:20-cv-05079 (E.D. Wash. Aug. 31, 2021).
    “An ALJ’s failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Coop v. Kijakazi, No. 4:20-cv-05153 (E.D. Wash. Oct. 1, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 18 such evidence was not considered[.]”
  • Rodriguez v. Kijakazi, No. 4:20-cv-05180 (E.D. Wash. Dec. 1, 2021).
    “An ALJ’s failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Anderson v. Kijakazi, No. 4:20-cv-05216 (E.D. Wash. Dec. 3, 2021).
    “An ALJ's failure to cite specific evidence does not indicate that 22 such evidence was not considered[.]”
  • Rainwater v. Kijakazi, No. 4:20-cv-05178 (E.D. Wash. Jan. 12, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 22 such evidence was not considered[.]”
  • Polnaszek v. O'Malley, No. 4:21-cv-05008 (E.D. Wash. Feb. 24, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 22 such evidence was not considered[.]”
  • Swift Eagle v. Kijakazi, No. 4:21-cv-05052 (E.D. Wash. May 11, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 20 such evidence was not considered[.]”
  • Sylvester v. O'Malley, No. 4:21-cv-05114 (E.D. Wash. June 13, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 20 such evidence was not considered[.]”
  • Arbuckle v. Kijakazi, No. 4:21-cv-05098 (E.D. Wash. Sept. 8, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 19 such evidence was not considered[.]”
  • Smith v. Kijakazi, No. 4:21-cv-05104 (E.D. Wash. Sept. 28, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 20 such evidence was not considered[.]”
  • Sanborn v. Kijakazi, No. 2:21-cv-00341 (E.D. Wash. Nov. 22, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 22 such evidence was not considered[.]”
  • Marino v. Kijakazi, No. 4:21-cv-05138 (E.D. Wash. Dec. 14, 2022).
    “An ALJ’s failure to cite specific evidence does not indicate that 20 such evidence was not considered[.]”
  • Turner v. Kijakazi, No. 4:21-cv-05135 (E.D. Wash. Mar. 3, 2023).
    “An ALJ’s failure to cite specific evidence does not indicate that 20 such evidence was not considered[.]”
  • Kanski v. Bisignano, No. 4:25-cv-05009 (E.D. Wash. July 24, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Ontiveros, No. 2:25-cv-00205 (E.D. Wash. Dec. 16, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Bowman, No. 4:25-cv-05058 (E.D. Wash. Dec. 17, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Ramos, No. 4:25-cv-05087 (E.D. Wash. Dec. 17, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Susan v. Bisignano, No. 1:25-cv-03018 (E.D. Wash. Aug. 4, 2025).
    “An ALJ’s failure to cite specific evidence does 15 not indicate that such evidence was not considered[.]”
  • Rivera v. Dudek, No. 2:25-cv-00001 (E.D. Wash. Aug. 7, 2025).
    “An ALJ’s failure to cite specific evidence does 18 not indicate that such evidence was not considered[.]”
  • Krenz v. Dudek, No. 4:24-cv-05145 (E.D. Wash. Apr. 9, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Deasy v. Dudek, No. 4:24-cv-05124 (E.D. Wash. Apr. 9, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Bowen v. Bisignano, No. 4:25-cv-05013 (E.D. Wash. Aug. 21, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • Hansen v. Dudek, No. 2:24-cv-00311 (E.D. Wash. Apr. 28, 2025).
    “An ALJ’s failure to cite specific evidence does 19 20 not indicate that such evidence was not considered[.]”
  • Lamere v. Dudek, No. 2:24-cv-00376 (E.D. Wash. Apr. 28, 2025).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Combs v. Bisignano, No. 4:25-cv-05003 (E.D. Wash. Aug. 29, 2025).
    “An ALJ’s failure to cite specific evidence does not 19 indicate that such evidence was not considered[.]”
  • Llamas v. Dudek, No. 4:24-cv-05122 (E.D. Wash. Apr. 29, 2025).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
  • West v. Bisignano, No. 2:25-cv-00012 (E.D. Wash. Sept. 10, 2025).
    “An ALJ’s failure to cite specific evidence does not 19 indicate that such evidence was not considered[.]”
  • Fink, No. 1:25-cv-03149 (E.D. Wash. Mar. 20, 2026).
    “An ALJ’s failure to cite specific evidence does not 21 indicate that such evidence was not considered[.]”
  • McConnell, No. 2:25-cv-00291 (E.D. Wash. Mar. 24, 2026).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Vannortrick, No. 1:25-cv-03165 (E.D. Wash. Apr. 21, 2026).
    “An ALJ’s failure to cite specific evidence does 19 not indicate that such evidence was not considered[.]”
  • Larsen, No. 1:25-cv-03201 (E.D. Wash. Apr. 17, 2026).
    “An ALJ’s failure to cite specific evidence does 16 not indicate that such evidence was not considered[.]”
  • Kesler, No. 4:25-cv-05130 (E.D. Wash. Mar. 27, 2026).
    “An ALJ’s failure to cite specific evidence does 22 not indicate that such evidence was not considered[.]”
At page 387 Evaluating disability determination based on work history and testimony25 citing casesfinding conservative treatment and no surgery consistent with discrediting claimant’s testimony3 citing courts put it this way · 24 listed here
Show 14 more citing cases
At page 385 Assessing substantial evidence supporting agency conclusions23 citing cases18 listed here
Show 8 more citing cases
At page 388 upholding denial of benefits where no objective medical evidence supported claimant’s subjective pain complaints2 citing cases1 citing court put it this way · 1 listed here
Retrieving the full opinion text from the archive…
56 soc.sec.rep.ser. 462, unempl.ins.rep. (Cch) P 16010b Phyllis Y. Black
v.
Kenneth S. Apfel, Commissioner, Social Security Administration
97-3384.
Court of Appeals for the Eighth Circuit.
Apr 23, 1998.
Published opinion
143 F.3d 383
1998 U.S. App. LEXIS 7783
1998 WL 191158
E. Gregory Wallace, Buies Creek, NC, argued (Anthony W. Bartels, on the brief), for Appellant., Steven A. Ford, Office of the General Counsel, Social Security Administration, Dallas, TX, argued (Robert T. Bowman, on the brief), for Appellee.
Loken, McMILLIAN, Wollman.
Cited by 509 opinions  |  Published
15 passages pin-cited by 57 cases
Pinpoint authority: #617 of 633,719
Citer courts: E.D. Washington (53)
WOLLMAN, Circuit Judge.

Phyllis Y. Black appeals the district court's [1] judgment affirming the denial of her application for social security disability benefits. We affirm.

I.

Phyllis Y. Black is a forty-nine-year-old woman who earned a high school degree and attended Y% years of college. Her past relevant work includes experience as a receptionist, word processing secretary, statistical word processor, and receptionist/inventory clerk. On December 17, 1993, Black filed applications for social security disability insurance benefits and supplemental security income. Alleging a disability onset date of December 31, 1992, Black claimed that she was unable to work, due to scoliosis, carpal tunnel syndrome, headaches, depression and a nervous condition. [2] The Social Security Administration denied her applications initially and again on reconsideration. Following a hearing, an administrative law judge (ALJ) found that Black was not disabled. Pursuant to regulatory guidelines promulgated at 20 C.F.R. § 416.920(a) — (f), the ALJ found that Black had not engaged in substantial gainful activity since December of 1992 and concluded that although she suffered from residuals from severe scoliosis and headaches, Black did not have an impairment or combination of impairments equivalent to a listed impairment. The ALJ further found that Black’s impairments did not prevent her from performing her past relevant work. See Bowen v. Yuckert, 482 U.S. 137, 140-42, 107 S.Ct. 2287, 2291-92, 96 L.Ed.2d 119 (1987) (describing the five-step eligibility analysis). After applying principles we set forth in Polaski v. Heckler, 739 F.2d 1320, 1322 (8th Cir.1984) (subsequent history omitted), the ALJ further concluded that Black’s subjective allegations of disabling pain were not credible.

The Appeals Council denied Black’s request for further review, and she subsequently sought judicial review pursuant to 42 U.S.C. § 405(g). The district court granted the Commissioner’s motion for summary judgment, finding that substantial evidence supported the Commissioner’s decision to deny Black’s benefits.

II.

We will uphold the Commissioner’s determinations if they are supported by substantial evidence on the record as a whole. See Spradling v. Chater, 126 F.3d 1072, 1073-74 (8th Cir.1997). Substantial evidence is relevant evidence which a reasonable mind would accept as adequate to support the Commissioner’s conclusion. See Woolf v. Shalala, 3 F.3d 1210, 1213 (8th Cir.1993). “In assessing the substantiality of the evidence, we must consider evidence that detracts from the [Commissioner’s] decision as well as evidence that supports it.” Id. We may not reverse the Commissioner merely because substantial evidence exists supporting a different outcome. See Smith v. Shalala, 987 F.2d 1371, 1374 (8th Cir.1993).

We first address Black’s argument that the ALJ failed to consider the opinion of her treating physician, Dr. G. Randall Gun-tharp, who wrote to the Social Security Administration urging that Black be granted disability benefits. Dr. Guntharp’s letter, characterizing Black’s scoliosis as “extreme,” stated that it was only after his urging that Black applied for benefits and that Black “is much more handicapped than many of the people presently receiving disability.” Black[*386] argues that the letter represented Dr. Gun-tharp’s opinion that she was disabled. She contends that the ALJ was compelled by our decision in Prince v. Bowen, 894 F.2d 283, 285 (8th Cir.1990), to discuss Guntharp’s opinion. In Prince we held that “[a]n ALJ’s failure to consider or discuss a treating physician’s opinion that a claimant is disabled constitutes error where, as here, the record contains no contradictory medical opinion.” Id. at 285-86.

The ALJ’s decision discussed the medical evaluations contained in Dr. Gun-tharp’s letter and noted relevant information from the doctor’s treatment notes. Although the ALJ apparently incorporated Dr. Gun-tharp’s findings into his decision, he did not specifically discredit the physician’s conclusions. Black, contending that the letter was an unequivocal statement of Dr. Guntharp’s opinion, alleges this was an error. Although required to develop the record fully and fairly, an ALJ is not required to discuss every piece of evidence submitted. See Miller v. Shalala, 8 F.3d 611, 613 (8th Cir.1993) (per curiam). An ALJ’s failure to cite specific evidence does not indicate that such evidence was not considered, see Montgomery v. Chater, 69 F.3d 273, 275 (8th Cir.1995). Given the ALJ’s specific references to the medical findings set forth in Dr. Guntharp’s letter, it is highly unlikely that the ALJ did not consider and reject Dr. Guntharp’s opinion that Black was disabled as a result of her extreme scoliosis.

Black also argues that the ALJ improperly discredited her subjective complaints of pain. “As is true in many disability cases, there is no doubt that the claimant is experiencing pain; the real issue is how severe that pain is.” Woolf, 3 F.3d at 1213. In analyzing a claimant’s subjective complaints of pain, an ALJ must examine: (1) the claimant’s daily activities; (2) the duration, frequency, and intensity of the pain; (3) dosage, effectiveness, and side effects of medication; (4) precipitating and aggravating factors; and (5) functional restrictions. See Polaski, 739 F.2d at 1322. Other relevant factors include the claimant’s relevant work history and the absence of objective medical evidence to support the complaints. See id. The ALJ may discount subjective complaints of pain if inconsistencies are apparent in the evidence as a whole. See Spradling, 126 F.3d at 1075.

Applying the Polaski directives, the ALJ examined the objective medical evidence of Black’s physiological impairments and the inconsistencies in Black’s claims and determined that Black’s subjective complaints of disabling pain lacked credibility. The ALJ observed that although Black complained of debilitating pain, she was still able at times to engage in many normal daily activities including household work, visiting friends, and attending church. See Lawrence v. Chater, 107 F.3d 674, 676 (8th Cir.1997). The ALJ also noted that although Black does experience some limitation, pain, and discomfort, she has never undergone surgery and has relied on a conservative course of treatment, including exercises, home cervical traction, a back brace, and medication. [3] See Robinson v. Sullivan, 956 F.2d 836, 840 (8th Cir.1992).

Black claims that physical activity frequently precipitates and aggravates her severe pain. The ALJ cited Black’s daily activities as inconsistent with her assertions. It was for the ALJ to resolve any contradictory evidence of Black’s functional limitations. See Bentley v. Shalala, 52 F.3d 784, 787 (8th Cir.1995) (“Where the medical evidence is equally balanced, as we find it is here, the ALJ resolves the conflict.”).

The objective medical evidence revealed scoliosis, spondylolisthesis, [4] and headaches. The ALJ correctly found that no diagnostic tests or objective medical findings existed to support Black’s carpal tunnel syndrome and psychological claims. Black was also getting some relief from her medications and physi[*387] cal therapy, while Dr. Guntharp’s records reveal a diminishing concern for her back problems. See Marciniak v. Shalala, 49 F.3d 1350, 1354 (8th Cir.1995) (idiopathic scoliosis requiring surgery was not a disabling condition).

Black’s lengthy work history supports her subjective complaints of disabling pain. As the ALJ found, however, offsetting this work history is the fact that (1) Black was laid off from her position, rather than forced out due to her condition, see Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir.1992); (2) she continued to seek work after her alleged disability onset date, see Bentley, 52 F.3d at 786; and (3) she continued to receive unemployment benefits after her alleged disability onset date, see Barrett v. Shalala, 38 F.3d 1019, 1024 (8th Cir.1994).

Black contends that the ALJ improperly rejected the lay testimony of her parents. Black’s parents were not qualified to give an opinion regarding her capacity to work, however, and their testimony merely corroborated Black’s testimony regarding her activities. The ALJ, having properly discredited Black’s complaints of pain, was equally empowered to reject the cumulative testimony of her parents. See Ostronski v. Chater, 94 F.3d 413, 419 (8th Cir.1996). The ALJ’s decision, which reflects a proper application of the Polaski factors, is supported by the record as a whole.

Finally, Black argues that the ALJ’s determination that she can return to her past relevant work is not supported by substantial evidence. She contends that her work as a receptionist/inventory clerk is beyond her residual functional capacity for light work. Black’s past relevant work, however, includes her experience as a receptionist, a position classified as having sedentary work requirements. See Dictionary of Occupational Titles, § 237.367-038 (4th ed. rev.1991); see also Evans v. Shalala, 21 F.3d 832, 834 (8th Cir.1994). Thus, we conclude that the ALJ’s determination that Black could return to her past relevant work is consistent with his findings regarding Black’s residual functional capacity.

The judgment is affirmed.

1

. The Honorable Jerry W. Cavaneau, United States Magistrate Judge for the Eastern District of Arkansas, to whom the case was referred for final disposition by consent of the parties pursuant to 28 U.S.C. § 636(c).

2

. Scoliosis is a lateral curvature of the spine. See The Sloane-Dorland Annotated Medical-Legal Dictionary, p. 471 (1992 Supp.). Carpal tunnel syndrome is "compression of the median nerve in the carpal tunnel, with pain and burning or tingling paresthesias in the fingers and hand, sometimes extending to the elbow.” Id. at 501.

3

. The record reflects that Black’s medication protocol included muscle relaxants and anti-inflammatory drugs. Of the several other prescribed medications that Black lists, some were recommended for unrelated conditions such as sinus and chest ailments.

4

. Spondylolisthesis is the forward displacement of one vertebra over another. See The Sloanc-Dorland Annotated Medical-Legal Dictionary at 483.