AKIM LITTLE v. COMMISSIONER OF SOCIAL SECURITY (2026)

MEMORANDUM & ORDER

Plaintiff Akim Little brings this action under 42 U.S.C. § 405(g), seeking judicial review of the Commissioner of Social Security's final decision denying her application for disability insurance benefits.

The parties consented to the undersigned's jurisdiction in this matter. Dkt. No. 11. Presently before the Court are the parties’ cross-motions for judgment on the pleadings. See Dkt. Nos. 7, 9. Having considered the parties’ pleadings, briefs, and the administrative record, the Court DENIES Plaintiff's motion and GRANTS the Commissioner's motion.

I. Regulatory Framework for Determining Disability Insurance Benefits

Disability insurance benefits are “available to individuals who are disabled.” Spencer v. Comm'r of Soc. Sec., No. 25-CV-5087 (OEM), 2026 WL 2168877, at *3 (E.D.N.Y. July 28, 2026). “A person is disabled if they are unable ‘to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.’ ” Id. (quoting 42 U.S.C. § 423(d)(1)(A)); see also 20 C.F.R. § 404.1509.

The Social Security Administration (SSA) Administrative Law Judge (ALJ) employs “a ‘five-step sequential evaluation process’ to determine whether a claimant is disabled, proceeding through each step until they reach a determination.” Sanchez v. Comm'r of Soc. Sec., No. 25-CV-353 (OEM), 2026 WL 91629, at *4 (E.D.N.Y. Jan. 13, 2026) (citing 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4)); see also Nunez v. Comm'r of Soc. Sec., 164 F.4th 60, 67-68 (2d Cir. 2025) (describing the five-step process). The claimant bears the burden of proof in the first four steps of the inquiry, and the burden shifts to the Commissioner at step five. See Sanchez, 2026 WL 91629, at *4 (citation omitted); see also Sczepanski v. Saul, 946 F.3d 152, 158 (2d Cir. 2020) (“The claimant has the general burden of proving that he or she has a disability within the meaning of the Act, and bears the burden of proving his or her case at steps one through four. At Step Five, the burden shifts to the Commissioner to show there is other work that the claimant can perform.” (citation omitted)).

“Pursuant to this five-step inquiry, the ALJ first determines whether the claimant is currently engaged in ‘substantial gainful activity.’ ” Agueda v. Comm'r of Soc. Sec., No. 24-CV-2466 (DG), 2025 WL 2653845, at *2 (E.D.N.Y. Sep. 16, 2025) (quoting 20 C.F.R. § 404.1520(a)(4)(i)). “If the answer is yes, the claimant is not disabled, regardless of the claimant's medical condition or the claimant's age, education, and work experience.” Id. (citing 20 C.F.R. § 404.1520(a)(4)(i), (b)). “If the answer is no, the ALJ proceeds to the second step to determine whether the claimant has a ‘severe medically determinable physical or mental impairment that meets the [applicable] duration requirement ․ or a combination of impairments that is severe and meets the duration requirement.’ ” Id. (quoting 20 C.F.R. § 404.1520(a)(4)(ii)).

“An impairment or combination of impairments is severe when it ‘significantly limits [the claimant's] physical or mental ability to do basic work activities.’ ” Id. (quoting 20 C.F.R. § 404.1520(c)). “If the impairment or combination of impairments is not severe, the claimant is not disabled.” Id. (citing 20 C.F.R. § 404.1520(a)(4)(ii), (c)); see also Spencer, 2026 WL 2168877, at *3 (“If a claimant does not have a severe impairment or combination of impairments that meets the durational requirement, then the claimant is not disabled, and the inquiry stops there.” (citing 20 C.F.R. § 404.1520(a)(4))).

“If the claimant satisfies her burden at the first two steps – demonstrating that she is not engaged in substantial gainful activity and that she has a severe impairment or combination of impairments – the ALJ proceeds to the third step of the inquiry.” Agueda, 2025 WL 2653845, at *2. “At that step, the ALJ considers whether any of the claimant's impairments meets or equals one of the impairments listed in the applicable regulations (the ‘Listings’) and meets the duration requirement.” Id. (first citing 20 C.F.R. § 404.1520(a)(4)(iii); and then citing 20 C.F.R. pt. 404, subpt. P, app. 1). “If yes, the claimant is disabled and eligible for benefits; if not, the SSA moves to step four.” Nunez, 164 F.4th at 67.

“At step four, the SSA determines whether the claimant can perform any of their past relevant work based on an assessment of the claimant's ‘residual functional capacity’ [(RFC)].” Id. at 67-68 (citing 20 C.F.R. § 416.920(a)(4)(iv)). “RFC is defined as an individual's ability to do physical and mental work activities on a sustained basis despite limitations imposed by [the claimant's] impairment.” Colas v. Comm'r of Soc. Sec. Admin., No. 23-CV-7838 (PKC), 2026 WL 866221, at *2 (E.D.N.Y. Mar. 30, 2026) (quoting Medina v. Comm'r of Soc. Sec., No. 13-CV-2323 (KAM), 2016 WL 4402010, at *10 (E.D.N.Y. Aug. 18, 2016)); see also 20 C.F.R. § 416.945(a)(1). “To determine the plaintiff's RFC, the ALJ must consider the plaintiff's ‘impairment(s), and any related symptoms, such as pain, [that] may cause physical and mental limitations that affect what [the plaintiff] can do in a work setting.’ ” Colas, 2026 WL 866221, at *2 (quoting 20 C.F.R. § 404.1545(a)(1)). “In determining a plaintiff's RFC, the ALJ must consider all impairments, including those that [the ALJ] concluded were not severe.” Id. (internal quotation marks and citation omitted); see also 20 C.F.R. § 404.1545(a)(2), (e). “The ALJ is responsible for assessing the plaintiff's RFC ‘based on all the relevant evidence in the case record.’ ” Colas, 2026 WL 866221, at *2 (quoting Pellot v. Comm'r of Soc. Sec., No. 18-CV-3337 (AMD), 2019 WL 3500919, at *1 (E.D.N.Y. July 31, 2019)). “The ALJ must then use the RFC finding to determine if the plaintiff can perform past relevant work.” Id. at *3 (citing 20 C.F.R. § 404.1520(a)(4)(iv)).

“If the claimant can perform any of their past relevant work, the claimant is not disabled”; but “[i]f the claimant cannot, then at the fifth and final step, the SSA evaluates whether there are significant numbers of jobs in the national economy that the claimant can perform given the claimant's [RFC], age, education, and work experience.” Nunez, 164 F.4th at 68 (internal quotation marks and citation omitted). “If at this stage the SSA is unable to show that other such jobs exist, the claimant is entitled to benefits; otherwise, the claimant is deemed not disabled.” Id.; see also Agueda, 2025 WL 2653845, at *2 (“At step five, an ALJ must determine whether the claimant – given the claimant's RFC, age, education, and work experience – can make an adjustment to other work that exists in significant numbers in the national economy.” (citing 20 C.F.R. §§ 404.1520(a)(4)(v), (g)-(h), 404.1560(c))).

II. Plaintiff's Disability Insurance Benefits Application and the ALJ's Findings

Plaintiff, who is currently fifty years old, initially filed a claim with the SSA for a period of disability and disability insurance benefits in September 2019. See Tr. at 67.¹ After a telephone hearing, ALJ Michelle I. Allen denied Plaintiff's application on September 17, 2021, finding that Plaintiff had the RFC for a range of light work with postural limitations and, accordingly, was not disabled as defined in the Social Security Act. See id. at 10, 67-77. The Appeals Council dismissed Plaintiff's request for the review of the decision as untimely (id. at 83-87) and Plaintiff did not further appeal.

On October 1, 2022, Plaintiff filed the current claim with the SSA for a period of disability and disability insurance benefits, alleging disability beginning on October 1, 2021. Id. at 10. This claim was denied initially on June 16, 2023, and denied again upon reconsideration on January 8, 2024. Id. Plaintiff filed a written request for a hearing, which was received by the SSA on January 17, 2024. Id. On August 7, 2024, ALJ Sandra M. McKenna held a telephone hearing. Id.; see also id. at 46-63 (transcript of hearing). Plaintiff's counsel attended the hearing, as did Andrew Vaughn, an impartial vocational expert. Id. at 10.

On October 2, 2024, “[b]ased on the application for a period of disability and disability insurance benefits filed on October 1, 2022,” ALJ McKenna held that “the claimant was not disabled under sections 216(i) and 223(d) of the Social Security Act through December 31, 2023, the last date insured.” Id. at 22.

Pursuant to the five-step sequential evaluation process (20 C.F.R. § 404.1520(a)(4)), ALJ McKenna found at step one that Plaintiff had not engaged in substantial gainful activity during the period from her alleged onset date of October 1, 2021 through her date last insured of December 31, 2023. Tr. at 13.

At step two, ALJ McKenna determined that Plaintiff experienced the severe impairments of “lumbar spondylitis, asthma, hypertension, and obesity.” Id. ALJ McKenna determined that Plaintiff “also has the non-severe impairments of hypokalemia and hypomagnesemia,” but noted that these impairments “do not cause more than minimal limitations in [Plaintiff's] ability to perform basic work activities and are therefore not severe.” Id.

At step three, ALJ McKenna found that, “[t]hrough the date last insured, [Plaintiff] did not have an impairment or combination of impairments that met or medically equaled the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1.” Id. (citing 20 C.F.R. §§ 404.1520(d), 404.1525, 404.1526). ALJ McKenna then assessed that, through the date last insured, Plaintiff “had the [RFC] to perform a sedentary work as defined in 20 CFR 404.1567(a) except: climb ramps, stairs, ladders, ropes, and scaffolds occasionally; balance, stoop, kneel, crouch, and crawl occasionally; never tolerate concentrated exposure to dust, odors, fumes and pulmonary irritants; and use of cane for ambulation.” Id. at 14; see also id. at 14-20.

At steps four and five, ALJ McKenna determined that, while Plaintiff had “no past relevant work,”² “[t]hrough the date last insured, considering the claimant's age, education, work experience, and [RFC], there were jobs that existed in significant numbers in the national economy that the claimant could have performed.” Id. at 20-21 (citing 20 C.F.R. §§ 404.1565, 404.1569, 404.1569a). Accordingly, ALJ McKenna concluded that Plaintiff was not disabled and, therefore, not eligible for disability insurance benefits from October 1, 2021, the alleged date of onset, through December 31, 2023, the date last insured. Id. at 22.

Plaintiff subsequently requested review by the SSA Appeals Council and was denied, thereby rendering ALJ McKenna's decision the final decision of the Commissioner. See id. at 1-6. Plaintiff now appeals ALJ McKenna's decision to this Court. See Dkt. No. 1. The parties subsequently filed their cross-motions for judgment on the pleadings. See Dkt. Nos. 7, 9.

III. Standard of Review

“Unsuccessful claimants for disability benefits under the Act may bring an action in federal district court seeking judicial review of the Commissioner's denial of benefits.” Colas, 2026 WL 866221, at *4 (citing 42 U.S.C. § 405(g)). “A district court's review of an ALJ's decision is limited to determining (1) whether the ALJ's findings are supported by substantial evidence and (2) whether the ALJ applied the correct legal standards.” Bahadur v. Dudek, No. 25-CV-1483 (OEM), 2026 WL 472556, at *2 (E.D.N.Y. Feb. 19, 2026) (citing 42 U.S.C. § 405(g)); see also Nasti v. Comm'r of Soc. Sec., No. 25-CV-3255 (MKB), 2026 WL 1620651, at *5 (E.D.N.Y. June 5, 2026) (“In reviewing a final decision of the Commissioner, a district court must determine whether the correct legal standards were applied and whether substantial evidence supports the decision.” (first quoting Butts v. Barnhart, 388 F.3d 377, 384 (2d Cir. 2004), as amended on reh'g in part, 416 F.3d 101 (2d Cir. 2005); and then citing Selian v. Astrue, 708 F.3d 409, 417 (2d Cir. 2013) (per curiam))). “The Court may ‘enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the Commissioner of Social Security, with or without remanding the cause for a rehearing.’ ” Spencer, 2026 WL 2168877, at *3 (quoting 42 U.S.C. § 405(g)); see also Colas, 2026 WL 866221, at *4 (“In addition to its authority to affirm, modify, or reverse a final decision, the Court may remand the case for the ALJ to further develop the record, resolve conflicts and ambiguities, or elucidate his or her rationale.” (collecting cases)).

The “substantial evidence” standard is “ ‘very deferential,’ ‘even more so than the “clearly erroneous” standard.’ ” Benjamin v. Comm'r of Soc. Sec., No. 25-2343, 2026 WL 697004, at *1 (2d Cir. Mar. 12, 2026) (quoting Schillo v. Kijakazi, 31 F.4th 64, 74 (2d Cir. 2022)). More specifically, “[s]ubstantial evidence means more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Ferraro v. Saul, 806 F. App'x 13, 14 (2d Cir. 2020) (quoting Moran v. Astrue, 569 F.3d 108, 112 (2d Cir. 2009)); see also Benjamin, 2026 WL 697004, at *1 (“Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” (quoting Schillo, 31 F.4th at 74)). Under this standard, “once an ALJ finds facts, we can reject those facts only if a reasonable factfinder would have to conclude otherwise.” Anthony v. Saul, No. 24-2163, 2025 WL 2848224, at *1 (2d Cir. Oct. 8, 2025) (quoting Brault v. Soc. Sec. Admin., Comm'r, 683 F.3d 443, 448 (2d Cir. 2012)); see also Talyosef v. Saul, 848 F. App'x 47, 48 (2d Cir. 2021) (quoting same). “Indeed, under the substantial evidence standard, the SSA's determination must be upheld if it is rational and supported by the record, even ‘[i]f [the] evidence is susceptible to more than one rational interpretation.’ ” Nunez, 164 F.4th at 70 (first quoting Schillo, 31 F.4th at 74; and then citing Brault, 683 F.3d at 448). “If, however, the Commissioner's decision is not supported by substantial evidence or is based on legal error, a court may set aside the Commissioner's decision.” Nasti, 2026 WL 1620651, at *5 (collecting cases).

IV. Discussion

Plaintiff argues that ALJ McKenna failed to develop the record, that ALJ McKenna's RFC findings are not supported by substantial evidence, and that ALJ McKenna did not “apply the relevant legal standards.” Dkt. No. 7-1 at 8-13.³ The Commissioner argues that substantial evidence supports ALJ McKenna's RFC assessment because the evidence reflects Plaintiff's ability to perform sedentary jobs and Plaintiff cannot show that “any rational factfinder would have been compelled to weigh the evidence differently.” Dkt. No. 9-1 at 14-20. The Court discusses the parties’ arguments in turn below.

A. ALJ McKenna Fulfilled Her Duty to Develop the Record

“Before deciding whether the ALJ's decision is supported by substantial evidence, the Court must first determine whether the ALJ fulfilled [the ALJ's] duty to fully develop the record.” Macchia v. Comm'r of Soc. Sec., No. 25-CV-5084 (HG), 2026 WL 2607725, at *3 (E.D.N.Y. Sep. 3, 2026) (internal quotation marks and citation omitted).

Plaintiff contends that ALJ McKenna failed to “take the simple step of requesting specificity from the consulting examiners regarding [P]laintiff's functional capabilities,” even though Plaintiff's counsel “twice suggested” to ALJ McKenna that “in order to establish [P]laintiff's functional abilities fully and precisely,” ALJ McKenna should “order another consultative medical examination or, alternatively, seek the opinions of another medical expert (presumably by means of testimony or by answers to written interrogatories).” Dkt. No. 7-1 at 12 (citing Tr. at 53, 62). Further, Plaintiff argues that ALJ McKenna “took no steps to obtain clarity and certainty in connection with the issue of [P]laintiff's capabilities to meet all of the demands of sedentary work” and therefore failed to fully develop the record. Id.

An ALJ, however, “is not required to further develop the record where the evidence present is sufficient for the ALJ to make a determination.” Macchia, 2026 WL 2607725, at *3 (citations omitted); see also Janes v. Berryhill, 710 F. App'x 33, 34 (2d Cir. 2018) (“The ALJ is not required to develop the record any further when the evidence already presented is ‘adequate for [the ALJ] to make a determination as to disability.’ ” (quoting Perez v. Chater, 77 F.3d 41, 48 (2d Cir. 1996))). “Where there are gaps in the administrative record or the ALJ has applied an improper legal standard, [courts] have, on numerous occasions, remanded to the [Commissioner] for further development of the evidence.” Rosa v. Callahan, 168 F.3d 72, 82-83 (2d Cir. 1999) (citations omitted); see also Spencer, 2026 WL 2168877, at *3 (“ ‘When there are gaps in the administrative record or the ALJ has applied an improper legal standard,’ remand for further development of the record is appropriate.” (quoting Pratts v. Chater, 94 F.3d 34, 39 (2d Cir. 1996))). But there is a flip side to that coin: “where there are no obvious gaps in the administrative record, and where the ALJ already possesses a ‘complete medical history,’ the ALJ is under no obligation to seek additional information in advance of rejecting a benefits claim.” Rosa, 168 F.3d at 79, n.5; see also Manzoor v. Comm'r of Soc. Sec., No. 20-CV-5559 (ARL), 2024 WL 1241988, at *6 (E.D.N.Y. Mar. 22, 2024) (“[W]here the claimant's treating physicians do not provide specific function-by-function assessments of the claimant's residual functional capacity, but the medical record is extensive enough to support an informed residual functional capacity finding by the ALJ, remand is not appropriate.” (collecting cases)).

Here, Plaintiff does not identify any “obvious gaps in the administrative record” that ALJ McKenna would need to fill. Instead, the administrative record “reflects a complete medical history sufficient to support the ALJ's decision.” Macchia, 2026 WL 2607725, at *3; see also Schillo, 31 F.4th at 76 (explaining that there “was a complete record before the ALJ consisting of medical opinions, treatment notes, and test results ․, as well as [the claimant's] own testimony”). In making the RFC finding, ALJ McKenna considered all symptoms and the extent to which these symptoms could be reasonably accepted as consistent with the objective medical evidence and other evidence pursuant to 20 C.F.R. § 404.1529 and SSR 16-3p, 2017 WL 5180304 (Oct. 25, 2017). See Tr. at 14-20 (discussing and citing relevant portions of the record). Further, ALJ McKenna considered the medical opinions and prior administrative medical findings in accordance with the requirements of 20 C.F.R. § 404.1520c. See id. at 14, 19-20.

At best, Plaintiff appears to argue that ALJ McKenna should have inquired further into the opinion of occupational medicine expert Ram Ravi, M.D., the doctor who conducted the consultative orthopedic examination of Plaintiff on December 18, 2023. Dkt. No. 7-1 at 11-12; Tr. at 17. Plaintiff argues that “[n]othing in Dr. Ravi's evaluation suggests that [Plaintiff] can consistently meet the sedentary-work requirements for standing, walking, lifting, carrying, and stooping.” Dkt. No. 7-1 at 11. But as the Commissioner correctly notes, Plaintiff's argument is “indistinguishable from the one rejected in” a similar case in this district, Oliveira v. Comm'r of Soc. Sec. Admin., No. 23-CV-8551 (OEM), 2024 WL 4710754 (E.D.N.Y. Nov. 7, 2024). Dkt. No. 9-1 at 18. In Oliveira, Dr. Ravi determined that the claimant had “[n]o limitations sitting” but had “[m]oderate to marked limitations standing, walking, bending, pushing, pulling, lifting, and carrying.” 2024 WL 4710754, at *6. The claimant in Oliveira argued that “despite Dr. Ravi's conclusion that Oliveira has ‘[m]oderate to marked limitations [for] standing, walking, bending, pushing, pulling, lifting, and carrying[,]’ the ALJ ‘insisted that Dr. Ravi's assessment does not preclude sedentary work inasmuch as the doctor's finding of moderate-to-marked restrictions is ‘vague.’ ” Id. at *5 (citation omitted). The Oliveira court, however, found that the claimant's argument was without merit: “Plaintiff's criticism of the ALJ's purported failure to develop the record fails because even if the record were robust regarding Plaintiff's struggles standing, etc., that determination would have little to no bearing on Plaintiff's sitting and her ability to perform sedentary work.” Id.

Here, following his December 18, 2023 consultative examination of Plaintiff, Dr. Ravi “indicated diagnoses of back pain, hypertension, and asthma; and opined that [Plaintiff] had no limitations in sitting, though moderate limitations in bending and overhead reaching; and moderate to marked limitations in standing, walking, pushing, pulling, lifting, and carrying, and she should avoid smoke, dust, and other respiratory irritants and triggers due to her history of asthma.” Tr. at 17; see also id. at 814-15. Like in Oliveira, any additional inquiry would not change Dr. Ravi's finding that Plaintiff “had no limitations on sitting.” See Oliveira, 2024 WL 4710754, at *5 (“In short, because the ALJ's RFC determination that Plaintiff can perform sedentary work was based on Dr. Ravi's determination that Plaintiff had ‘[n]o limitations sitting,’ Plaintiff's attacks on secondary issues related to the record's development, are unavailing.” (citation omitted)). Indeed, ALJ McKenna determined that “Dr. Ravi's opinion that there is no sitting limitation is more consistent with the overall record, including test results and examination findings, which do not support a moderate limitation in sitting.” Tr. at 20.

And, as the Court noted in Oliveira, Plaintiff—not ALJ McKenna—“bears the burden of proof in the first four steps of the sequential inquiry.” Oliveira, 2024 WL 4710754, at *5 (citing Smith v. Berryhill, 740 F. App'x 721, 726 (2d Cir. 2018)). Plaintiff has failed to meet that burden here and thus has not, and cannot, point to any relevant gaps in the record that warranted further development by ALJ McKenna. As the Commissioner correctly notes, “the record contains a detailed functional assessment from [Disability Determination Services (DDS) consultant S. Jacob, M.D.], who considered Dr. Ravi's ‘moderate to marked’ limitations and found them compatible with a reduced range of light work.” Dkt. No 9-1 at 19 (citing Tr. at 99-101; 20 C.F.R. § 404.1513a(b)(1) (recognizing State agency consultants as “highly qualified and experts in Social Security disability evaluation”)).

Accordingly, ALJ McKenna did not err in failing to supplement the administrative record.

B. ALJ McKenna's Findings Are Supported by Substantial Evidence

Plaintiff argues that “the record is devoid of substantial evidence that [Plaintiff] is capable of performing sustained, competitive sedentary work.” Dkt. No. 7-1 at 12. Specifically, Plaintiff asserts that “the ALJ's functional determination is not grounded in solid evidence but rather is the product of speculation.” Id. at 13.

“The Second Circuit has explained that while the SSA makes the ultimate finding of whether a claimant is disabled, where the record includes the opinions of treating physicians, the [SSA] considers the data that [their opinions] provide [and then] draws its own conclusions as to whether those data indicate disability.” James v. Comm'r of Soc. Sec., No. 23-CV-3688 (NRM), 2026 WL 305068, at *4 (E.D.N.Y. Feb. 5, 2026) (internal quotation marks omitted) (quoting Schillo, 31 F.4th at 70); see also Nasti, 2026 WL 1620651, at *9 (noting that “the Court is not required to give controlling weight to a plaintiff's physician when the opinion is unsupported or inconsistent with the record” (citations omitted)). “When evaluating medical source opinions, an ALJ is required to explicitly explain how he or she considered supportability and consistency, and may, but is not required to, provide an explicit explanation of the other factors” that are considered in evaluating the persuasiveness of medical opinions, including the relationship with the claimant (including length, purpose, and extent of the treatment relationship, the frequency of examinations, and the examining relationship), the medical professional's specialization, and other factors that tend to support or contradict a medical opinion or prior administrative finding. Id. (citing 20 C.F.R. § 404.1520c(b)(2), (c)). Still, supportability and consistency are the most important factors to consider when evaluating the persuasiveness of medical opinions or prior administrative medical findings. 20 C.F.R. § 404.1520c(a). As to supportability, “[t]he more relevant the objective medical evidence and supporting explanations presented by a medical source are to support his or her medical opinion(s) ․, the more persuasive the medical opinions ․ will be.” Id. § 404.1520c(c)(1). As to consistency, “[t]he more consistent a medical opinion(s) ․ is with the evidence from other medical sources and nonmedical sources in the claim, the more persuasive the medical opinion(s) ․ will be.” Id. § 404.1520c(c)(2).

Here, ALJ McKenna determined that through the date last insured, Plaintiff “had the [RFC] to perform a sedentary work as defined in 20 CFR 404.1567(a) except: climb ramps, stairs, ladders, ropes, and scaffolds occasionally; balance, stoop, kneel, crouch, and crawl occasionally; never tolerate concentrated exposure to dust, odors, fumes and pulmonary irritants; and use of cane for ambulation.” Tr. at 14-20. ALJ McKenna cited to clinical records showing “mild to moderate findings from the alleged onset date through the next year, with minimal treatment provided”; recent records showing Plaintiff's “cane did not appear to be medically necessary” at all times; and records showing “conservative” medical treatments, with no hospitalizations “for her severe impairments during the period at issue.” Id. at 19. ALJ McKenna evaluated the assessment of consultative examiner Olga Yevsikova, M.D., who performed a consultative orthopedic examination on April 10, 2023 and whose opinion that Plaintiff had moderate difficulty sitting was inconsistent with Dr. Ravi's later assessment on December 13, 2023 that Plaintiff had no difficulty sitting. Id. at 19-20. ALJ McKenna also evaluated Dr. Ravi's assessment of “moderate to marked” limitations for Plaintiff's ability to stand, walk, push, pull, lift, and carry, which were only partially supported by his own examination and which were inconsistent with Dr. Yevsikova's less-restrictive opinions. Id.

Additionally, ALJ McKenna evaluated the assessments of DDS medical consultants K. Ahmed, M.D., and Dr. Jacob, including findings that Plaintiff could perform a reduced range of light work, which were mostly consistent with each other, except that Dr. Jacob recommended slightly greater postural limitations and no restriction on respiratory irritants. Id. at 20. ALJ McKenna evaluated the opinions of Chukwuebuka Udokwu, M.D. as well, which ALJ McKenna determined were not supported by the other medical evidence in the record and were “not entirely consistent with the other, better-supported, opinions of record.” Id. ALJ McKenna explained her analysis of supportability and consistency for each of these medical opinions in detail, discussing the relevance, supporting explanations, and consistency of each of the opinions. Id. at 19-20. ALJ McKenna also considered Plaintiff's hearing testimony, which ALJ McKenna found to be “not entirely consistent with the medical evidence and other evidence in the record.” Id. at 18.

Significantly, ALJ McKenna found that Dr. Udokwu's opinions “are not persuasive as to sitting or lifting/carrying, as the medical evidence of record does not support such extreme limitations, including the treatment notes of record, and are not entirely consistent with the other, better-supported, opinions of record.” Id. at 20 (citing id. at 819-41). Dr. Udokwu's assessment, dated July 29, 2024, states that Dr. Udokwu treated Plaintiff from 2016 to 2018 for bilateral sciatica, scoliosis of lumbar spine, and osteoarthritis of the lumbar spine. Id. at 842-43. Plaintiff's symptoms were chronic lower back pain with radiation to both feet and numbness and tingling of both feet. Id. As ALJ McKenna noted, Dr. Udokwu opined that Plaintiff “was able to lift and carry less than 10 pounds occasionally and frequently, and to sit for less than 4 hours and stand/walk less than 2 hours in an 8-hour workday,” as well as “constantly use the hands for fine and gross motor activities,” but Plaintiff could reach in all directions only “less than occasionally (less than 1/3 of an 8-hour workday)” and would need to adjust her posture “every few minutes.” Id. at 18, 842-43. In Dr. Udokwu's July 25, 2024 treatment records, Dr. Udokwu noted that Plaintiff was “unable to lift 10 pounds, unable to stand” for more than hour, unable to walk for more than thirty minutes, unable to “reach overhead,” and unable to sit for more than four hours. Id. at 844. As ALJ McKenna noted, it was unclear whether these limitations were reported by Plaintiff and/or an opinion generated by Dr. Udokwu. Id. at 18. Nonetheless, the “extreme limitations” stated in Dr. Udokwu's July 29, 2024 assessment are not supported by the other medical evidence in the record, including the treatment records. Id. at 20. As discussed by ALJ McKenna, treatment records showed that Plaintiff reported lower back pain in January and April 2024 but ambulated without a cane and with a normal gait. See id. at 17-18, 20, 822-28. In July 2024 examination records, Plaintiff's gait was mildly antalgic and no assistive device was used. Id. at 17, 819-21. While Plaintiff “continued to have tenderness and reduced range of motion of the lumbar spine on each date, and muscle spasm,” Plaintiff “also continued to be able to perform normal activities of daily living, with no difficulty doing errands alone.” Id. at 17, 819-21. Accordingly, Plaintiff has identified no error in ALJ McKenna's analysis of the record—and specifically of Dr. Udokwu's assessment, which a reasonable factfinder could find was not persuasive.

At bottom, ALJ McKenna determined that the medical reports “indicate that while it is uncontroverted that [Plaintiff] has severe impairments causing more than minimal limitations in her ability to perform work functions and limiting her to the range of sedentary work detailed above, including requiring the use of a cane, these have not been shown to be so severe as to preclude her from performing work within this range on a regular and sustained basis.” Id. at 18-19. ALJ McKenna has built “an accurate and logical bridge from the evidence to her conclusion to enable meaningful review.” Gladys G. v. Comm'r of Soc. Sec., No. 22-CV-3554 (VEC) (GRJ), 2023 WL 5020343, at *4 (S.D.N.Y. May 22, 2023) (citation omitted), report and recommendation adopted, 2023 WL 4348720 (S.D.N.Y. July 3, 2023). Plaintiff's conclusory arguments amount to mere disagreements with ALJ McKenna's weighing of the evidence, which are “not tantamount to a finding that ‘no reasonable factfinder’ could have concluded otherwise.” Bahadur, 2026 WL 472556, at *7 (collecting cases).

Accordingly, ALJ McKenna's decision, including her findings as to Plaintiff's RFC, is supported by substantial evidence.

C. ALJ McKenna Applied the Proper Legal Standards

Plaintiff argues, again in a conclusory manner, that ALJ McKenna did not properly apply the relevant legal standards. See Dkt. No. 7-1 at 8. But Plaintiff fails to identify “which legal standards [ALJ McKenna] purportedly misapplied, and such a conclusory assertion, without more, is insufficient to warrant remand.” Macchia, 2026 WL 2607725, at *5 (citing Pezza v. Comm'r of Soc. Sec., No. 19-CV-3254 (BMC), 2020 WL 3503170, at *4 (E.D.N.Y. June 29, 2020) (“It is well-settled that ‘issues adverted to in a perfunctory manner, unaccompanied by some effort at developed argumentation, are deemed waived.’ ”)).

Notwithstanding Plaintiff's failure to articulate what legal standards ALJ McKenna allegedly misapplied, the Court has reviewed ALJ McKenna's five-step analysis in its entirety for legal error and has found none.

V. Conclusion

For the foregoing reasons, the Commissioner's decision is AFFIRMED, and this case is DISMISSED with prejudice. The Clerk of the Court shall enter final judgment in a separate document as required by Rule 58 of the Federal Rules of Civil Procedure and close this case.

SO ORDERED.

FOOTNOTES

1.   Citations to “Tr.” refer to the Certified Administrative Transcript filed at Dkt. No. 5 and its corresponding pages stamped in the lower right corner of each page.

2.   ALJ McKenna also noted that Plaintiff was forty-seven years old on the date last insured; that Plaintiff has “at least a high school education”; and that transferability of job skills is “not an issue because [Plaintiff] does not have past relevant work.” Tr. at 21.

3.   Page citations to the parties’ briefing are to the ECF-stamped pages unless otherwise noted.

JOSEPH A. MARUTOLLO United States Magistrate Judge