Case Law Update: Post v. Bisignano — Eighth Circuit Affirms SSDI Denial Where Daily Activities Supported a Records Reviewer

On August 28, 2026, the U.S. Court of Appeals for the Eighth Circuit affirmed the denial of Social Security disability insurance benefits in Rachael Post v. Frank Bisignano, Commissioner of Social Security Administration, No. 25-2081. Rachael Michelle Post appealed after the U.S. District Court for the Eastern District of Missouri, Judge Rodney W. Sippel, upheld the denial. The panel — Circuit Judges Kelly, Grasz, and Kobes, with Judge Kobes writing — affirmed in a published opinion, holding the administrative law judge’s residual functional capacity finding was supported by substantial evidence.

What the record showed

Post stopped working a retail job on June 3, 2016 after surgery on her right hand and forearm, and sought benefits for a closed period running to August 5, 2021. She was later diagnosed with thoracic outlet syndrome and underwent thoracic outlet release surgeries on her left shoulder in March 2017, her right shoulder that September, and both shoulders in April 2019. Several treating sources imposed a five-pound lifting limit.

On August 8, 2017, Dr. John Marshall Jung, an ophthalmologist, reviewed Post’s records for the Social Security Administration and concluded that she “could frequently lift up to ten pounds and had no limitations when it came to reaching, handling, or fingering.” The ALJ found Post retained the residual functional capacity for sedentary work — defined by regulation as “lifting no more than 10 pounds at a time and occasionally lifting or carrying articles like docket files, ledgers, and small tools” (20 C.F.R. § 404.1567(a)) — so long as she avoided climbing, and that she could frequently handle, finger, and reach. A vocational expert testified that a significant number of jobs existed with those limitations, and the ALJ found Post was never disabled.

The standard the court applied

The Eighth Circuit reviewed the district court’s decision de novo but the agency’s decision deferentially. Quoting Andrews v. Colvin, 791 F.3d 923, 928 (8th Cir. 2015), it repeated that “Substantial evidence is less than a preponderance but enough that a reasonable mind would find it adequate to support the conclusion.” Reversal is not available because “we would have decided the case differently” (Krogmeier v. Barnhart, 294 F.3d 1019, 1022 (8th Cir. 2002)); the decision may be disturbed only if it fell “outside the available zone of choice” (Bonham v. Bisignano, 177 F.4th 934, 942 (8th Cir. 2026)).

On medical opinions, the court restated the five factors from Bowers v. Kijakazi, 40 F.4th 872, 875 (8th Cir. 2022): “ALJs evaluate the persuasiveness of medical opinions by considering (1) whether they are supported by objective medical evidence, (2) whether they are consistent with other medical sources, (3) the relationship that the source has with the claimant, (4) the source’s specialization, and (5) any other relevant factors.” Supportability and consistency are the most important of the five.

Why the appeal did not succeed

Post argued the ALJ should not have relied on Dr. Jung’s opinion, conceding at oral argument that if that reliance was proper, her claim fails. Her first challenge was that daily activities such as light housework do not establish an ability to work full time, citing Hogg v. Shalala, 45 F.3d 276, 278 (8th Cir. 1995). The court disagreed: “But Post did more than just ‘light housework.’ She drove, walked her dog, threw a nerf football, and frequently did housework.” It held: “It was reasonable for the ALJ to find that these activities supported Dr. Jung’s conclusion that she could lift more than five pounds and undermined contrary medical opinions.”

Her second challenge was that Dr. Jung reviewed the file before two more surgeries and roughly four more years of treatment. The court acknowledged that new evidence “after the medical source made his or her medical opinion” may make it “less persuasive” under 20 C.F.R. § 404.1520c(c)(5), but held that does not automatically make reliance an error. Because the record showed Post recovered full range of motion and normal strength after each surgery, the panel found that “her subsequent recoveries are consistent with Dr. Jung’s opinion that she could lift up to ten pounds.” It added: “The weighing of evidence is ultimately reserved to the ALJ.”

What this means if you have an SSDI claim

• Function reports are evidence. The ALJ relied on Post’s own 2017 function report alongside the medical records. What a claimant reports doing can be read against a restrictive lifting limit, so accuracy and context matter in describing a typical day.
• Exam findings can outweigh a treating source’s restriction. Several of Post’s providers wrote a five-pound limit, but the same charts recorded full range of motion and normal grip strength. Under Bonham, 177 F.4th at 944–45, courts “uphold ALJ decisions that weigh conflicting medical evidence and reach a conclusion that does not comport with all the medical evidence.”
• An older record review is not automatically discounted. Later surgeries and years of added treatment did not, by themselves, disqualify a 2017 file review here. The regulation asks for a showing that the intervening evidence changed the functional picture, not just that more treatment happened.
• Specialization is one of the five factors. The reviewing consultant here was an ophthalmologist assessing upper-extremity limits. The opinion does not address any argument about his specialty; the analysis turned on supportability and consistency. Whether a source’s field fits the impairment is still a listed factor.
• The hearing builds the record a court later reads. Substantial-evidence review is deferential, so the place to shape the record is the ALJ hearing.

The Eighth Circuit does not bind Florida claims, which fall in the Eleventh Circuit, but the medical-opinion factors under 20 C.F.R. § 404.1520c apply nationwide. If your disability claim was denied and you are considering an appeal, our team offers a free case evaluation. For background on the process, see our complete guide to SSDI benefits and the application process.

This article summarizes a publicly available court decision as of August 29, 2026 and is for general information. It is not legal advice, and no attorney-client relationship is created by reading it. Every claim turns on its record.