Kaitlin Welch v. Frank Bisignano, Commissioner of Social Security Administration1

23-3019Court of Appeals for the Eighth CircuitJan 30, 2026

Full text

United States Court of Appeals
For the Eighth Circuit
___________________________
No. 24-3616
___________________________
Kaitlin Welch
lllllllllllllllllllllPlaintiff - Appellant
v.
Frank Bisignano, Commissioner of Social Security Administration1
lllllllllllllllllllllDefendant - Appellee
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Appeal from United States District Court
for the District of Minnesota
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Submitted: December 18, 2025
Filed: January 9, 2026
[Unpublished]
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Before SMITH, GRUENDER, and KOBES, Circuit Judges.
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1Frank Bisignano has been appointed to serve as Commissioner of Social
Security, and is substituted as appellee pursuant to Federal Rule of Appellate
Procedure 43(c).

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PER CURIAM.
Kaitlin Welch appeals the district court’s2 order affirming the denial of disabled
child’s insurance benefits and supplemental security income. We agree with the court
that substantial evidence in the record as a whole supports the adverse decision. See
Cropper v. Dudek, 136 F.4th 809, 813 (8th Cir. 2025) (standard of review).
Specifically, substantial evidence supported the administrative law judge’s
(ALJ’s) findings that Welch did not have the medically determinable impairments of
fibromyalgia, autism spectrum disorder, and attention deficit hyperactivity disorder,
and that Welch’s migraine headaches were a non-severe impairment; further, the ALJ
considered Welch’s pain and overlapping mental health symptoms in making the
residual functional capacity (RFC) determination. See Grable v. Colvin, 770 F.3d
1196, 1200-02 (8th Cir. 2014) (affirming where ALJ considered claimant’s pain in
determining RFC, but did not include fibromyalgia because specialists found she did
not meet criteria, despite other physicians’ diagnoses of fibromyalgia); Gallus v.
Callahan, 117 F.3d 1061, 1064-65 (8th Cir. 1997) (substantial evidence supported
ALJ’s finding that claimant did not have mental impairment; diagnosis by one
provider was not supported by record, and other providers had concluded claimant
had no such impairment); Trenary v. Bowen, 898 F.2d 1361, 1364 (8th Cir. 1990)
(critical question in disability claim is not diagnosis, but rather functional limitations
imposed by impairment).
We also find that the ALJ did not err in evaluating the opinions of Welch’s
psychiatric nurse practitioner, the medical expert at the first hearing, or Welch’s
partner, grandmother, and case worker. See Perkins v. Astrue, 648 F.3d 892, 901 (8th
2The Honorable Dulce J. Foster, United States Magistrate Judge for the District
of Minnesota, to whom the case was referred for final disposition by consent of the
parties pursuant to 28 U.S.C. § 636(c).
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Cir. 2011) (substantial evidence supported ALJ’s decision to discredit family
members’ statements because statements were inconsistent with record and were
likely influenced by their affection for claimant); Juszczyk v. Astrue, 542 F.3d 626,
632 (8th Cir. 2008) (ALJ properly discounted physician’s opinion because it was
inconsistent with physician’s treatment notes, objective testing, and other medical
evidence of record). Substantial evidence supported the ALJ’s determinations that
Welch’s subjective complaints were not fully consistent with the record, and that
Welch’s RFC did not include any manipulative limitations. See Schwandt v.
Berryhill, 926 F.3d 1004, 1012 (8th Cir. 2019) (ALJ properly discredited claimant’s
complaints based on objective medical evidence, treatment records, and daily
activities); Wildman v. Astrue, 596 F.3d 959, 969 (8th Cir. 2010) (ALJ did not err in
failing to include limitation in RFC, as he determined that claimant’s allegations
about such limitation were not credible).
Given the proper RFC determination, substantial evidence also supported the
ALJ’s conclusion, based on the vocational expert’s (VE’s) testimony, that Welch was
not disabled. See Kraus v. Saul, 988 F.3d 1019, 1027 (8th Cir. 2021) (VE’s
testimony constituted substantial evidence because it responded to hypothetical with
impairments accepted as true by ALJ and reflected in RFC). Finally, we find no merit
to Welch’s arguments that the occupations cited by the VE in response to the ALJ’s
hypothetical conflicted with the RFC determination. While the ALJ must resolve
conflicts between the VE’s testimony and the Dictionary of Occupational Titles
(DOT), see Moore v. Colvin, 769 F.3d 987, 989-90 (8th Cir. 2014), no such conflict
existed here.
The judgment is affirmed.
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