20 C.F.R. § 404.1545
Residual functional capacity: the cases that interpreted this section
9,670 citing cases reviewed of 11,963 in the citation index: 6,798 interpreted the section (annotated below), 2,872 cited it only in passing. Cases filed after 2026-06-18 may not have been reviewed yet.
Have a situation under 20 C.F.R. § 404.1545?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Mental work capacity
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.
Moehlenpah v. Berryhill · filed 2019-09-27(a)(1)
RFC is defined as “the most [a claimant] can do despite [his or her] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... In sum, the Court finds that the ALJ thoroughly reviewed the information regarding Plaintiff’s panic attacks and concludes that the ALJ’s finding regarding Plaintiff’s ability to perform a limited range of light work, as stated in the RFC, is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a) describes residual functional capacity as a claimant’s work-related abilities despite limitations.
Meadows v. Commissioner of Social Security · filed 2019-09-27(a)
A claimant’s RFC is an indication of an individual’s work-related abilities despite their limitations.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite her limitations.
Lancaster v. Social Security Administration, Commissioner of · filed 2019-09-27(a)(1)
An RFC is the most a claimant can do despite her limitations. 20 C.F.R. §§ 404.1545(a)(1) and 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite impairments.
Dillinger v. Social Security Administration, Commissioner of · filed 2019-09-27(a)(1)
A claimant’s RFC is the most that claimant can do despite his or her impairments.Read the full opinion on CourtListener →
An RFC assessment must account for supported limitations in concentration, persistence, pace, and social functioning.
Gillespie v. Commissioner of Social Security · filed 2019-09-23
Remand is required for the ALJ to discuss the opinions of Dr. Hill and Dr. Gange and to explain how their opinions regarding Ms. G.’s moderate limitations in concentration, persistence, and pace and in social functioning are taken into consideration in the RFC.Read the full opinion on CourtListener →
An RFC assessment need not include limitations attributed to an impairment when substantial evidence shows that the impairment caused no significant work limitations lasting twelve months.
Larson v. Saul · filed 2019-09-23
Substantial evidence supports the ALJ’s conclusion that Plaintiff had no significant limitations caused by her head injury that met the twelve-month durational requirement and that would have more than minimally affected her ability to work. Therefore, the ALJ was under no obligation to include limitations related to her head injury in his RFC assessment.Read the full opinion on CourtListener →
Section 404.1545(a) allows an RFC limited to simple, routine, repetitive tasks when that limitation accounts for the claimant’s supported memory impairments.
Fielder v. Commissioner of Social Security · filed 2019-09-26(a)
Mr. F.’s impairments relate largely to memory, which are accommodated by the limitation to simple, routine, and repetitive tasks. Mr. F. has not shown that the record supports greater restrictions than those in the RFC.Read the full opinion on CourtListener →
In assessing residual functional capacity, an ALJ may consider conservative, sporadic mental health treatment when deciding whether mental impairments warrant functional restrictions.
Hawkins v. Commissioner, Social Security Administration · filed 2019-09-12(e)
Plaintiff’s complaint is addressed to the ALJ’s failure to incorporate Dr. Morton’s suggested restrictions in her residual functional capacity assessment at step four of the sequential evaluation. See 20 C.F.R. § 404.1545(e). In the context of that determination, it was entirely appropriate for the ALJ to correlate plaintiff’s conservative, sporadic treatment to a finding that his mental impairments were not so disabling as to warrant any particular functional restrictions.Read the full opinion on CourtListener →
Residual functional capacity must account for limitations supported by the medical record, including mental limitations.
Snider v. Commissioner of Social Security · filed 2019-09-12(a)(1)
Without further analysis here, the Court directs the ALJ on remand to ensure that all of Snider’s limitations supported by the medical record, including all mental limitations, are incorporated into his RFC.Read the full opinion on CourtListener →
A residual functional capacity limited to simple tasks does not account for a claimant’s limitation in concentration, persistence, or pace.
Dale v. Saul · filed 2019-09-12
Even if supported by substantial evidence, limitations to work with simple tasks do not “account for a limitation in concentration, persistence or pace.”Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can do despite physical or mental limitations.
Stomer v. Commissioner of Social Security · filed 2019-09-13(a)
Regulations define RFC as “what [the claimant] can do” despite her “physical or mental limitations.” 20 C.F.R. § 404.1545(a). ... In conclusion, the Court finds that the ALJ’s RFC determination is consistent with the relevant evidence of record including the objective medical evidence, the observations of medical providers, as well as the evaluation of Plaintiff’s subjective complaints.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.
Dzafic v. Berryhill · filed 2019-09-16(a)(1)
Prior to Step Four, the Commissioner must assess the claimant’s “residual functional capacity” (“RFC”), which is “the most a claimant can do despite [his or her] limitations.” Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009) (citing 20 C.F.R. § 404.1545(a)(1)); see also 20 C.F.R. § 404.1520(e).Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite impairments.
Dick v. Berryhill · filed 2019-09-16
RFC is defined as the most one can do despite one’s impairments. 20 C.F.R. § 404.1545.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.
Hope v. Social Security Administration, Commissioner of · filed 2019-09-17(a)(1)
An RFC is the most a claimant can do despite his limitations.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite her limitations.
Valle v. Social Security Administration, Commissioner of · filed 2019-09-18(a)(1)
An RFC is the most a claimant can do despite her limitations. 20 C.F.R. §§ 404.1545(a)(1) and 416.945(a)(1).Read the full opinion on CourtListener →
An RFC assessment under § 404.1545 need not include a claimed bathroom limitation when substantial evidence supports its omission.
Meister v. Berryhill · filed 2019-09-20(a)(1)
The Court concludes that the ALJ’s decision not to include a bathroom limitation in Meister’s RFC was supported by substantial evidence in the record.Read the full opinion on CourtListener →
Section 404.1545 permits an RFC assessment with broader social interaction limits when the record does not establish a need for a more specific limit.
Colon v. Commissioner of Social Security · filed 2019-09-05
Based upon my review of the RFC assessment and the record evidence, I am satisfied that the ALJ’s determination is supported by substantial evidence and that remand is not warranted because of the ALJ’s failure to reference issues, or include in the RFC specific limitations, relating to Colon’s ability to interact with men.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to address a claimant’s ability to interact with supervisors when evidence of that limitation could affect the work the claimant can perform.
Parato v. Berryhill · filed 2019-09-11(a)
Thus, because the ALJ repeatedly highlighted Plaintiff’s limited ability to interact with supervisors but failed to address his finding of no limitation, a finding that significantly impacts the testimony of the VE, remand is appropriate so Plaintiff’s ability to interact with supervisors may be fully considered.Read the full opinion on CourtListener →
An RFC assessment may omit a limitation on interaction with supervisors when substantial evidence supports that omission.
Thomas v. Commissioner of Social Security · filed 2019-09-06
Therefore, along with the medical records previously discussed, I find substantial evidence supports the ALJ’s decision not to include a social functioning limitation with respect to supervisors in Thomas’s RFC.Read the full opinion on CourtListener →
An RFC assessment must consider a claimant’s mental impairments, whether or not they are severe.
Schink v. Commissioner of Social Security · filed 2019-08-27
Severe or not, the ALJ was required to consider Schink’s mental impairments in the RFC assessment but evidently failed to do so.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to assess work-related mental abilities when determining residual functional capacity, considering all relevant evidence.
Bosse v. Social Security Administration · filed 2019-08-23(c)
In formulating the RFC, an ALJ must perform a function-by-function assessment of these work-related functions, considering all of the relevant evidence in the case record.Read the full opinion on CourtListener →
Section 404.1545(c) requires an assessment of mental abilities when determining residual functional capacity.
HARDY v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-08-14(c)
Plaintiff also points to the requirements stated in 20 C.F.R. § 404.1545(c), which mandates an assessment of mental abilities as part of the residual functional capacity determination at step four. ... Plaintiff has argued persuasively that the ALJ erred in making the residual functional capacity determination, failing to address the medical evidence of nonexertional limitations. The residual functional capacity determination is not supported by substantial evidence.Read the full opinion on CourtListener →
A residual functional capacity assessment must account for a claimant’s accepted limitations in pace.
(SS) Twilley v. Commissioner of Social Security · filed 2019-08-09(a)
Because the ALJ did not address Plaintiff’s difficulties in pace, the RFC did not adequately address Plaintiff’s limitations.Read the full opinion on CourtListener →
Section 404.1545(c) requires a mental residual functional capacity assessment to consider the person’s ability to understand, carry out, and remember instructions and to respond appropriately to supervision, co-workers, and work pressures.
Gregory VAN HORN, Appellant, v. Margaret M. HECKLER, Secretary, Department of Health and Human Services, Appellee · filed 1983-09-23(c)
With mental impairments, the determination of residual functional capacity must include consideration of “ability to understand, to carry out and remember instructions, and to respond appropriately to supervision, co-workers and work pressures in a work setting.”Read the full opinion on CourtListener →
Section 404.1545(c) requires the Secretary to consider how mental impairments affect a claimant’s ability to relate to others, follow instructions, respond to supervision and coworkers, and handle customary work pressures.
Fyffe v. Heckler · filed 1984-01-24(c)
Although the AU’s finding is accurate as far as it goes, the AU apparently ignored Dr. Westman’s other conclusions that Fyffe is “moderately severely” impaired in his ability to relate to other people, ability to understand, remember, and carry out instructions, and respond appropriately to supervision, and that Fyffe is “severely” impaired in his ability to respond appropriately to co-workers, and customary work pressures. The regulations state that the Secretary will consider these factors. See 20 C.F.R. §§ 404.1545(c) and 416.945(c).Read the full opinion on CourtListener →
Section 404.1545(c) requires a mental residual functional capacity assessment to consider the claimant’s ability to understand, carry out, and remember instructions and respond appropriately to supervision, coworkers, and work pressures.
STOKES, Ellis, Appellant, v. Otis R. BOWEN, M.D., Secretary of U.S. Department of Health and Human Services · filed 1987-02-19(c)
The circular merely reiterates, virtually verbatim, the regulations by which the AU was already bound. ... Therefore, by his failure to make the inquiry mandated by the regulations, and to rely instead on Stokes’ so-called “work experience” and other evidence that had no direct bearing on Stokes’ ability to work, the Secretary did not demonstrate a “reasonable basis in law for the theory [he] propounds.”Read the full opinion on CourtListener →
Section 404.1545(c) requires consideration of a claimant’s ability to understand and follow instructions and respond appropriately to workplace supervision, coworkers, and pressures when assessing mental residual functional capacity.
Hawkins v. Heckler · filed 1985-01-22(c)
Residual functional capacity must, therefore, be determined according to 20 C.F.R. § 404.1545(c): (c) Mental impairments. When we assess your impairment because of mental disorders, we consider factors such as your ability to understand, to carry out and remember instructions, and to respond appropriately to supervision, coworkers and work pressures in a work setting.Read the full opinion on CourtListener →
Section 404.1545(c) makes a claimant’s mental limitations relevant to the ability to perform past or other work.
Davis v. Apfel · filed 1999-02-16(c)
The Court fails to see any basis for discounting Dr. Kaspar’s testimony. ... See 20 C.F.R. §§ 404.1545(c), 416.945(c) (“[a] limited ability to carry out certain mental activities, such as limitations in understanding, remembering, and carrying out instructions, ... may reduce your ability to do past work and other work.”) Dr. Kaspar’s statement that plaintiff could not perform even the slightest degree of physical exertion due to “pain and injury difficulties” does not transform his opinion into an opinion about plaintiffs physical tolerance, and the record does not reveal that the ALJ relied on Dr. Kaspar’s opinion in determining plaintiffs physical tolerance in addition to her mental capacity.Read the full opinion on CourtListener →
Section 404.1545(c) allows an ALJ to consider evidence beyond medical evidence when assessing mental residual functional capacity, but the assessment requires at least some supporting evidence from a professional.
Lauer v. Apfel · filed 2001-04-04(c)
Therefore, although in evaluating Mr. Lauer's RFC, see 20 C.F.R. § 404.1545(c), the ALJ was not limited to considering medical evidence, we believe that the ALJ was required to consider at least some supporting evidence from a professional.Read the full opinion on CourtListener →
Section 404.1545(c) includes following instructions, responding appropriately to supervision and co-workers, and handling work pressures among the mental activities relevant to residual functional capacity.
Mason v. Barnhart · filed 2004-07-12(c)
The relevant mental work activities include understanding, remembering and carrying out instructions; responding appropriately to supervision and co-workers; and handling work pressures in a work setting. 20 C.F.R. § 404.1545(c).Read the full opinion on CourtListener →
Section 404.1545(c) requires assessment of a claimant’s ability to understand, remember, and carry out instructions and respond appropriately to supervision, coworkers, and work pressures.
Wates v. Barnhart · filed 2003-06-30(c)
SSR 85-16; see also 20 C.F.R. § 404.1545(c) (stating that ALJ must assess the mental abilities of “understanding, remembering, and carrying out instructions, and in responding appropriately to supervision, co-workers, and work pressures in a work setting”). ... The ALJ did not engage in an explicit evaluation of plaintiffs mental RFC, finding only that she could perform simple, low stress work involving no contact with the public.Read the full opinion on CourtListener →
An ALJ’s mental residual functional capacity finding must account for earlier findings of deficiencies in concentration, persistence, and pace, but need not repeat the exact “B” criteria findings.
Ottman v. Barnhart · filed 2004-03-03
This case was remanded in order for the ALJ to provide a mental functional residual capacity findings that takes account for his earlier finding that Ms. Ottman “often” had deficiencies in concentration, persistence, and pace. Therefore, for the sake of clarification, this matter was remanded for further consideration of that issue, and was not remanded, to require the ALJ to include his exact “B” criteria findings into his RFC findings.Read the full opinion on CourtListener →
Section 404.1545(c) requires assessment of the nature and extent of a claimant’s mental limitations when determining residual functional capacity for regular and continuing work.
O'HALLORAN v. Barnhart · filed 2004-07-07(c)
In reaching this conclusion, the ALJ did not consider all of the pertinent evidence in the record and failed to follow the Commissioner’s regulations and guidelines for assessing mental residual functional capacity, as set forth in 20 C.F.R. § 404.1545 and Social Security Ruling 85-16. ... Therefore, the ALJ’s mental residual functional capacity assessment of plaintiff must be reversed.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to assess a claimant’s mental work abilities function by function before assigning vocational categories.
Lechner v. Barnhart · filed 2004-06-14(c)
In the present case, the ALJ failed to assess plaintiffs mental abilities on a function-by-function basis under § 404.1545(c). Instead, she proceeded to directly assign vocational categories without first evaluating functional capacity.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC assessment to account for all relevant evidence of a claimant’s work-related limitations.
Young, James v. Barnhart, Jo Anne · filed 2004-04-02(a)(1)
The RFC falls short because it fails to account for the evidence in the record regarding Young’s problems accepting instruction, responding appropriately to criticism from supervisors, thinking independently, and setting realistic goals.Read the full opinion on CourtListener →
An ALJ may address potential mental limitations in assessing residual functional capacity by relying on a medical report that considers them.
McKinney v. Barnhart · filed 2004-06-16(c)
The ALJ, however, specifically stated that his determination of McKinney’s RFC was based in part on the report of Dr. Larson, which addressed these potential limitations.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ assessing mental residual functional capacity to consider pertinent medical evidence about a claimant’s mental limitations.
La Patra v. Barnhart · filed 2005-12-08(c)
As the Commissioner concedes, in his decision the ALJ failed to assess plaintiffs residual functional capacity in accordance with the applicable regulations. See 20 C.F.R. §§ 404.1520a; 404.1545(c). The ALJ did not consider all the pertinent medical evidence in the record regarding plaintiffs mental impairments, nor did he explain why he relied on certain opinions of record and not others.Read the full opinion on CourtListener →
Section 404.1545(c) lists mental-activity limitations as examples, so an ALJ need not address every listed factor.
Lyons v. Commissioner of Social Security · filed 2004-12-29(c)
The factors in § 404.1545, however, are listed by way of example, as is indicated by the language of the regulation: “A limited ability to carry out certain mental activities, such as limitations in understanding, remembering, and carrying out instructions. ...” 20 C.F.R. § 404.1545(c).Read the full opinion on CourtListener →
An ALJ assessing mental residual functional capacity must explain the claimant’s specific mental abilities; an unexplained limit to simple, one- and two-step jobs is insufficient.
Witt v. Barnhart · filed 2006-08-22(c)
By simply setting out his “one- and two-step” conclusion without properly explaining the nature and extent of Witt’s mental strengths and weaknesses, the ALJ skipped too many intermediate steps en route to his mental RFC conclusions and VE hypothetical.Read the full opinion on CourtListener →
Section 404.1545(a) does not require an ALJ to address mental abilities in an RFC assessment when no physician identifies objective deficiencies in concentration or attention.
Smith v. Astrue · filed 2007-11-15(a)
No physician noted any objective deficiencies in Smith’s concentration or attention, so the ALJ did not have to address Smith’s mental abilities. 20 C.F.R. § 404.1545(a).Read the full opinion on CourtListener →
Residual functional capacity measures the most a claimant can do in a work setting despite physical and mental limitations.
Anderson v. Astrue · filed 2010-02-01(a)(1)
A claimant’s RFC represents “the most [the claimant] can do despite [any physical and mental] limitations” that affect “what [he] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1). ... Plaintiffs first contention, i.e., that the ALJ did not consider the impact of his mental impairments, is without merit.Read the full opinion on CourtListener →
Section 404.1545(c) requires an RFC assessment to consider how mental limitations affect a claimant’s ability to respond to supervision, co-workers, and work pressures and to perform past or other work.
Richards v. Astrue · filed 2010-04-13(c)
Although the ALJ apparently credited notations in Richards’s psychiatric records that she had depression, anxiety, irritability, difficulty controlling her anger, and problems with her social environment, the ALJ did not address how these limitations might impact Richards’s ability to respond appropriately to supervision, co-workers, and work pressures, or reduce her ability to do her past work or other work. See 20 C.F.R. § 404.1545(c); Villano, 556 F.3d at 563 (explaining that ALJ must evaluate all limitations that arise from medically determinable impairments, even those that are not severe).Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite the claimant’s limitations.
Rivera v. Commissioner of Social Security · filed 2010-07-21(a)(1)
RFC is defined in the applicable regulations as “the most [the claimant] can still do despite [his] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can still do despite impairments and is assessed using all relevant evidence, including medical evidence, treatment, physicians’ observations, and the claimant’s statements.
YTTRIE v. Astrue · filed 2010-07-26(a)
Residual functional capacity is a measure of the abilities which the claimant retains despite his or her impairment. 20 C.F.R. § 404.1545(a). The RFC assessment is based upon all of the relevant evidence, including objective medical evidence, treatment, physicians’ opinions and observations, and the claimant’s own statements about his limitations.Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as the most an individual can still do after considering physical limitations that affect work-related tasks.
Bauer v. Social Security Administration · filed 2010-08-24
RFC is defined in the Regulations as the most an individual can still do after considering the effects of physical limitations that can affect the ability to perform work-related tasks.Read the full opinion on CourtListener →
Section 404.1545 requires the residual functional capacity determination to include all of a claimant’s restrictions, including moderate limitations in concentration, persistence, or pace.
Lubin v. Commissioner of Social Security Administration · filed 2013-02-08
The ALJ must include all restrictions in the residual functional capacity determination and the hypothetical question posed to the vocational expert, including moderate limitations in concentration, persistence, or pace.Read the full opinion on CourtListener →
Section 404.1545(c) requires an RFC to account for a claimant’s established mental limitations, including limitations in concentration, persistence, and pace.
Misener v. Astrue · filed 2013-02-20(c)
Because the ALJ found that Misener suffers from moderate limitations in concentration, persistence and pace, but failed to incorporate those limitations into the RFC or the hypotheticals posed to the Vocational Expert, the decision of the Commissioner is REVERSED and REMANDED for further proceedings.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can still do despite limitations; a moderate social-functioning rating at step three does not automatically require a corresponding RFC restriction.
Beasley v. Astrue · filed 2013-04-10(a)
But the ALJ’s finding of “moderate difficulties” in social functioning in the “paragraph B” criteria does not necessarily translate to a work-related functional limitation for the purposes of the RFC assessment. The RFC is defined as “the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a).Read the full opinion on CourtListener →
Section 404.1545(a)(4) requires an RFC assessment to address the claimant’s ability to meet the mental requirements of work.
Farringer v. Colvin · filed 2013-09-17(a)(4)
An RFC must assess the claimant’s ability to meet the mental requirements of work, 20 C.F.R. § 404.1545(a)(4), which includes the ability to respond appropriately to coworkers and work pressures.Read the full opinion on CourtListener →
A residual functional capacity assessment evaluates a claimant’s ability to work despite impairments and is separate from the special technique used to evaluate mental impairments.
Jacobs v. Commissioner of Social Security · filed 2013-06-06(a)(1)
This technique, however, is separate from the ALJ’s evaluation of the claimant’s RFC assessment, the latter of which is an assessment of the claimant’s ability to do work despite his impairments.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite limitations and must account for the claimant’s mental impairments.
Mabry v. Colvin · filed 2016-03-03(a)(1)
We conclude that substantial evidence in the record supported the ALJ’s RFC determination and that the ALJ’s RFC determination included the necessary limitations to account for Mabry’s mental impairments.Read the full opinion on CourtListener →
An RFC assessment must account for moderate limitations in concentration, persistence, or pace; a restriction to simple, repetitive work does not automatically account for them.
Holland v. Commissioner of Social Security · filed 2016-07-19(a)(3)
Rather, it appears that the ALJ merely assumed that a limitation to simple, repetitive work automatically accounted for Holland’s moderate deficits in concentration and attention. ... Accordingly, the Commissioner’s final decision will be remanded for the purpose of reassessing.Holland’s mental RFC with respect to his moderate limitations in maintaining concentration, persistence, or pace.Read the full opinion on CourtListener →
An RFC assessment under § 404.1545 must account for supported limitations in attention and concentration.
Stephens v. Colvin · filed 2016-08-02(a)
A claimant’s RFC is the most he can do despite his limitations. 20 C.F.R. § 404.1545(a)(1). ... Even if Dr. Loomis’ conclusions were somewhat contradictory, both established some level of impairment of attention and concentration, which was supported by diagnostic tests. ... Due to the ALJ’s disregard of Dr. Loomis’ opinion regarding Plaintiffs attention and concentration testing, the Court finds Plaintiffs RFC is not supported by substantial evidence.Read the full opinion on CourtListener →
An RFC assessment must explain how a claimant with moderate limitations in concentration, persistence, or pace can meet workday productivity demands when the record raises that issue.
McLaughlin v. Colvin · filed 2016-08-03
Although “[i]t is reasonable to assume that [Plaintiffs] moderate limitations translate into a decrease in productivity,” ... the ALJ’s decision failed to address this issue and to explain how, despite Plaintiffs moderate difficulties in maintaining concentration, persistence, or pace, she could remain productive for at least 85% of the workday.Read the full opinion on CourtListener →
An RFC assessment need not include a limitation the ALJ finds unsupported by the record.
Adams v. Colvin · filed 2016-08-10
The ALJ is not required to incorporate limitations in the RFC that he did not find to be supported in the record.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an assessment of residual functional capacity to consider all relevant evidence about the functional effects of a claimant’s impairments.
Dean v. Colvin · filed 2016-10-03(a)(3)
While, as a general matter, a hearing officer has broad discretion to make factual findings and credibility determinations, the hearing officer here fell short of his obligations in evaluating the functional effects of Dean’s mental impairments.Read the full opinion on CourtListener →
An RFC assessment must account for a claimant’s limitations in concentration, persistence, and pace; a restriction to simple, routine, and repetitive tasks does not suffice when it fails to address those limitations.
Passig v. Colvin · filed 2016-12-19(a)(1)
These cases make it clear that if a claimant is found to have limitations in maintaining concentration, persistence and pace, those limitations must be spelled out in the RFC assessment and in the hypothetical question posed to the VE. ... The ALJ’s broad limitations of simple, routine, and repetitive tasks failed to address any of plaintiffs individualized problems. He did not include limited interaction with others, nor did he indicate how the limitations he did include addressed plaintiffs issues with concentration, persistence or pace. This is error.Read the full opinion on CourtListener →
An RFC assessment must address identified limitations in concentration and social functioning by including appropriate work restrictions or explaining their absence.
Proctor v. Colvin · filed 2017-01-17(a)(4)
Under Mascio, the ALJ, having found moderate deficiencies in maintaining concentration, persistence, or pace, was obligated to explain whether these deficiencies affected Claimant’s ability to perform sedentary work. It also follows from Mascio that the RFC assessment should similarly include either a limitation addressing social functioning or an explanation for the absence of such a limitation.Read the full opinion on CourtListener →
An RFC assessment may express a claimant’s stress limitations as specific work restrictions based on her subjective symptoms and the medical evidence.
Thompson v. Berryhill · filed 2017-09-18
I find that the ALJ did not commit such error here. Contrary to plaintiffs argument, the ALJ did not “define stress in an objective way.” Docket # 16, at 6. Instead, he based his definition of -stress on claimant’s subjective symptoms and the medical evidence of record. The ALJ defined the parameters of plaintiffs stress limitations and explained that plaintiffs limitations permitted her. to perform simple, routine tasks that do not require independent decision making and involve only occasional changes, in the work routine.Read the full opinion on CourtListener →
An RFC must account for limitations in concentration, persistence, or pace that affect a claimant’s ability to complete work tasks in a timely and appropriate manner.
Ostrander v. Berryhill · filed 2018-01-27(a)(4)
Here, the Court finds the ALJ failed to adequately account for Ms. Ostrander’s moderate limitations in concentration, persistence, or pace, in that the ALJ failed to include limitations for her ability to timely and appropriately complete tasks commonly found in work settings, an area in which the ALJ clearly found Ms. Ostrander had limitations.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to determine a claimant’s residual functional capacity based on all relevant evidence in the record.
Sunshine v. Berryhill · filed 2018-01-29(a)(1)
The ALJ is responsible for determining a claimant’s RFC based on all relevant evidence in the record.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can still do despite physical or mental limitations.
Porter v. Berryhill · filed 2018-03-07(a)
Residual functional capacity refers to what a claimant can still do despite physical or mental limitations.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite her limitations; the ALJ includes limitations supported by the record.
Finney v. Colvin · filed 2018-03-19(a)(1)
Once again, a claimant's RFC is the most she can still do despite her limitations. See 20 C.F.R. § 404.1545(a)(1). When determining a claimant's RFC, an ALJ need only incorporate those limitations which he finds are supported by the record.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite mental and physical limitations, assessed from all relevant evidence.
Quinn v. Berryhill · filed 2018-03-20(a)(1)
In order to complete step four, the Commissioner must determine the claimant’s RFC, which is the most the claimant can do despite the claimant’s mental and physical limitations. Brown v. Barnhart, 390 F.3d 535, 538-39 (8th Cir. 2004) (citing 20 C.F.R. § 404.1545(a)(1)). ... An ALJ determines a claimant’s RFC based on all relevant evidence in the record, including medical records, observations of treating physicians, and the claimant’s own description of her limitations. ... Thus, the court finds the ALJ’s mental RFC assessment is supported by substantial evidence in the record.Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ to consider physical and mental abilities, symptoms, pain, and other limitations when assessing residual functional capacity.
Price v. Berryhill · filed 2018-03-22(a)
An ALJ must determine an individual's RFC after considering her "physical abilities, mental abilities, symptomology, including pain and other limitations which could interfere with work activities on a regular and continuing basis."Read the full opinion on CourtListener →
An RFC assessment must account for mental limitations, including mild limitations from a nonsevere impairment, and explain their effect on work capacity.
Hearan v. Colvin · filed 2018-07-09(c)
On remand, the ALJ must explain what effect, if any, Claimant’s mild limitations in mental functioning had on her RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC assessment to consider all relevant evidence, including mild mental limitations, and to explain how those limitations are treated.
President v. Berryhill · filed 2018-09-07(a)(1)
On remand, the ALJ shall reevaluate Plaintiff's RFC, considering all of the evidence of record, including her mental limitations, and shall explain the basis of her findings in accordance with applicable regulations and rulings.Read the full opinion on CourtListener →
Section 404.1545(c) assesses mental limitations by their effect on the ability to work on a regular and continuing basis.
Anderson v. Berryhill · filed 2018-09-24(c)
In light of the temporary nature of the suggested work limitations, the ALJ did not err in finding that Dr. Logel’s diagnosis of a somatic symptom disorder would not affect Plaintiff’s RFC. See 20 C.F.R. §§ 404.1545(c), 416.945(c) (in assessing a claimant’s mental abilities, the ALJ considers the effects on work ability “on a regular and continuing basis”).Read the full opinion on CourtListener →
Section 404.1545(c) requires an assessment of mental work capacity on a regular and continuing basis, supported by evidence connecting medical findings to work functions.
Guttierez v. Berryhill · filed 2018-08-10(c)
Regardless of whether the ALJ properly discounted this opinion, she created a gap in the record when she rejected the only opinion as to Guttierez's mental ability to perform work-related functions on a regular and continuing basis. ... Without reliance on a medical source's opinion or a function-by-function assessment connecting the medical evidence to the RFC, the ALJ's decision leaves the Court with many unanswered questions and does not afford an adequate basis for meaningful judicial review. Accordingly, the Court finds that the ALJ's RFC assessment is not supported by substantial evidence and that remand is required.Read the full opinion on CourtListener →
A residual functional capacity assessment must account for supported mental limitations; an ALJ must explain how a restriction to simple, routine work addresses limitations in concentration, persistence, or pace.
Thigpen v. Berryhill · filed 2018-10-18(a)(1)
However, the ALJ failed to explain how those observations justify a conclusion that simple, routine work adequately addressed Plaintiff’s moderate limitations in concentration, persistence, or pace.Read the full opinion on CourtListener →
Mild limitations identified during the psychiatric review technique do not require corresponding residual functional capacity limitations.
Taylor v. Berryhill · filed 2018-10-29
Accordingly, mild limitations in daily living activities, social functioning, and with concentration, persistence, and pace do not require a corresponding RFC limitation as Plaintiff suggests.Read the full opinion on CourtListener →
An RFC assessment must account for moderate limitations in social interaction or explain, with record evidence, why no corresponding restriction is needed.
Dennis v. Berryhill · filed 2019-01-22(a)
This finding necessitates the ALJ include either a corresponding limitation in the RFC assessment or an explanation as to why one was not necessary.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC assessment based on all relevant evidence, including limitations from medically determinable mental impairments.
Judge v. Deputy Commissioner for Operations · filed 2019-01-28(a)(1)
In sum, remand is required because the ALJ failed to: 1) account for Plaintiff’s mental limitations in the RFC; 2) assess the combined impact of Plaintiff’s non-severe mental limitations with Plaintiff’s severe physical impairments in the RFC, and 3) properly explain his step two findings of mild mental limitations.Read the full opinion on CourtListener →
An RFC assessment need not include additional limitations for mild mental impairments when the objective evidence does not support them.
PETERMAN v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-05-31(a)
Consequently, based on substantial evidence, the ALJ reasonably concluded that, aside from limiting Plaintiff’s contact with others, the objective evidence failed to support additional or more restrictive limitations related to Plaintiff’s mild mental functional limitations or mental impairments.Read the full opinion on CourtListener →
An RFC limited to unskilled work can account for moderate difficulty with social interaction when the record supports that assessment.
Wilson v. Commissioner of Social Security Administration · filed 2019-06-05(a)(1)
So, by limiting Plaintiff to unskilled work, the ALJ imposed significant limitations that “account[] for [Plaintiff’s] difficulties with social interaction.”Read the full opinion on CourtListener →
An ALJ’s residual functional capacity assessment must account for the claimant’s limitations in concentrating, persisting, or maintaining pace.
Claggett v. Commissioner of Social Security · filed 2019-07-16(a)
Here, the ALJ’s RFC assessment did not properly account for Plaintiffs difficulties in concentrating, persisting, or maintaining pace.Read the full opinion on CourtListener →
An RFC limited to simple, routine tasks does not adequately account for moderate limitations in concentration, persistence, and pace.
Arapovic v. Saul · filed 2019-07-26
The ALJ’s limitation to simple, routine tasks is particularly problematic under Seventh Circuit precedent in light of Plaintiff’s acknowledged moderate limitations in concentration, persistence, and pace.Read the full opinion on CourtListener →
Section 404.1545(c) requires the assessment of mental limitations and their effect on a claimant’s ability to work when determining residual functional capacity.
Downey v. Saul · filed 2020-01-07(c)
Here, the ALJ recognizes that Plaintiff has severe mental health impairments, but the RFC does not identify their impact with a detailed function-by-function assessment.Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider the claimant’s limitations and either account for them or explain why a restriction is unnecessary.
Brown v. Berryhill · filed 2020-01-27(a)
Because the ALJ neither included a proper limitation in her RFC assessment nor explained why such a limitation was unnecessary in this case, the Court must remand the case to the SSA for further analysis consistent with Mascio.Read the full opinion on CourtListener →
Section 404.1545(c) requires a mental RFC assessment to address whether the claimant can sustain the identified work tasks throughout a full workday and workweek.
Oliver v. Berryhill · filed 2020-01-22(c)
The ALJ’s limitation for Plaintiff to “simple, routine, and repetitive tasks,” “simple work-related decisions,” and “occasional interaction with supervisors, co-workers, and the general public,” R. 22, does not account for whether Plaintiff can perform these tasks for a full workday and workweek.Read the full opinion on CourtListener →
Section 404.1545(c) allows an RFC limited to simple, routine, repetitive tasks to account for moderate concentration and persistence limitations when the record supports that assessment.
Holler v. Saul · filed 2020-01-29(c)
Accordingly, it is clear that the ALJ credited all of the medical evidence showing that Plaintiff had moderate limitations with regard to concentration and persistence, and incorporated those findings into the RFC by limiting Plaintiff to “simple, routine and repetitive non-complex tasks.” (See R. 19-24).Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider the entire record, including nonsevere impairments and functional limitations.
Bryan v. Berryhill · filed 2020-01-29(a)
In determining RFC specifically, an ALJ must consider the entire record, opinion evidence, impairments that are not severe, and any limitations the ALJ finds.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity must consider objective medical facts, diagnoses, medical opinions, and the claimant’s subjective symptoms and asserted limitations.
Lawler v. Commissioner of Social Security · filed 2020-01-30
In making an RFC assessment, the ALJ must consider objective medical facts, diagnoses, and medical opinions based on those facts, along with the claimant’s subjective symptoms of pain and other asserted limitations. 20 C.F.R. §§ 404.1545, 416.945.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations.
Brewer v. Social Security Administration, Commissioner · filed 2020-01-31(a)(1)
The regulations define RFC as “the most [a claimant] can still do despite [the claimant’s] limitations.” 20 C.F.R. § 404.1545(a)(1). ... Substantial evidence supports the ALJ’s RFC formulation.Read the full opinion on CourtListener →
A residual functional capacity assessment must distinguish limitations involving supervisors and coworkers from limitations on public contact.
(SS) Flores v. Commissioner of Social Security · filed 2020-01-31(a)(1)
Contrary to the Commissioner’s suggestion, an inability to appropriately interact with or respond to criticism from supervisors and coworkers, for example, is distinct from an inability to interact with the public. Indeed, the Social Security regulations treat the abilities to respond appropriately to “supervision” and to get along with “coworkers” as aspects of the “basic mental demands” of unskilled work, noting that the “substantial loss of ability to meet” any basic mental demand could “severely limit the potential occupational base.” 20 C.F.R. § 404.1545(a)(1); SSR 85-15 at *4.Read the full opinion on CourtListener →
Section 404.1545(e) requires an ALJ to consider the limiting effects of nonsevere impairments when assessing residual functional capacity; the ALJ may omit mental limitations when the evidence supports that decision.
Campbell v. Commissioner of Social Security · filed 2020-01-31(e)
Amy C. correctly asserts that theALJ must consider the limiting effects of all of a claimant’s impairments, even those impairments that are not severein determining the claimant’s RFC. 20 C.F.R. §§ 404.1545(e), 416.945(e). However, where the ALJ builds a logical bridge between the evidence and his decision to omit non-exertional mental limitations from the ultimate RFC finding, remand is not required.Read the full opinion on CourtListener →
Section 404.1545(a) permits an ALJ to assess residual functional capacity using all relevant medical and other evidence in the record.
Vitko v. Commissioner of Social Security · filed 2020-01-31(a)
The ALJ was acting within his discretion by assessing the plaintiff’s RFC based on “all of the relevant medical and other evidence” in the record. See 20 C.F.R. § 404.1545(a).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations, based on all relevant evidence.
Laura Love Thornton v. Berryhill · filed 2020-02-03(a)(1)
The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... The ALJ properly formulated Plaintiff’s RFC.Read the full opinion on CourtListener →
Section 404.1545(c) requires the ALJ to consider evidence of a claimant’s ability to understand, remember, carry out instructions, and respond appropriately in a work setting when assessing mental limitations.
Creggs v. Berryhill · filed 2020-02-05(c)
In determining the claimant’s mental limitations, the ALJ considers evidence of the claimant’s abilities to understand, remember, and carry out instructions, as well as respond appropriately to supervision, co-workers, and work pressures in a work setting. Id. § 404.1545(c). ... Because the record shows that the ALJ made the proper considerations in determining the RFC, the Court finds that the RFC is supported by substantial evidence and the ALJ made no error in his findings.Read the full opinion on CourtListener →
A claimant bears the burden of establishing her residual functional capacity with credible evidence of her limitations.
Gonzalez v. Commissioner of Social Security · filed 2020-02-06
The Commissioner argues correctly that it was Plaintiff’s burden, not the Commissioner’s, to establish her RFC.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite limitations.
Gonzalez v. Berryhill · filed 2020-02-10(a)(1)
An individual’s residual functional capacity (“RFC”) is the most an individual can still do despite his or her limitations. 20 CFR § 404.1545(a)(1). ... The Court therefore finds that the ALJ’s opinion is supported by substantial evidence.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite the claimant’s limitations.
STRICKLAND v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-02-10(a)(1)
“[R]esidual functional capacity is the most [a claimant] can still do despite [the claimant’s] limitations. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can still do despite physical or mental limitations; the assessment must be supported by evidence.
Edwards v. Saul · filed 2020-02-11(a)
RFC is defined as “what [the claimant] can still do” despite her “physical or mental limitations.” 20 C.F.R. § 404.1545(a). ... Although it is not necessary that an RFC finding be supported by a specific medical opinion, the ALJ did not cite to any evidence in support of his determination. ... Thus, the ALJ’s RFC determination is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires the ALJ to consider impairments and related symptoms that may limit a claimant’s ability to work when assessing residual functional capacity.
Bourdier v. Berryhill · filed 2020-02-12(a)(1)
To determine the claimant’s RFC, the ALJ must consider the claimant’s “impairment(s), and any related symptoms . . . [which] may cause physical and mental limitations that affect what [the claimant] can do in a work setting.” ... Accordingly, the Court finds that the ALJ’s conclusion that Plaintiff’s mental impairments did not meet the requisite de minimis level of severity, even if erroneous, was harmless because the ALJ considered Plaintiff’s mental impairments as part of the RFC determination.Read the full opinion on CourtListener →
A residual functional capacity assessment may exclude concentration limitations when substantial evidence supports that finding.
Contreras v. Berryhill · filed 2020-02-10(a)
Thus, the Court finds that the ALJ did not err in excluding concentration issues from the RFC.Read the full opinion on CourtListener →
Section 404.1545(c) requires the ALJ to assess a claimant’s ability to follow simple instructions and respond appropriately to supervision, coworkers, and work pressures when determining mental capacity.
Reading v. Berryhill · filed 2020-03-02(c)
When a claimant suffers from a mental impairment the ALJ must analyze mental capacity including the ability to understand, carry out and remember simple instructions, and to respond appropriately to supervision, coworkers and work pressures. 20 C.F.R. § 404.1545(c); see also Medical-Vocational Guidelines, 20 C.F.R. Part 404, Subpart P, Appendix 2.Read the full opinion on CourtListener →
An ALJ must account for supported limitations in concentration, persistence, and pace when assessing residual functional capacity.
Austin v. Saul · filed 2020-03-23(a)(2)
Accordingly, on remand the ALJ should first reconsider Austin’s concentration limitations and include good reasons supported by substantial evidence for the limitation. Then the ALJ should ensure that Austin’s limitation in concentration, persistence, and pace is included in the hypothetical questions posed to the VE and in the RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations; the assessment must reflect limitations supported by the record.
Shiwbodh v. Berryhill · filed 2020-03-23(a)(1)
An individual’s residual functional capacity (“RFC”) is the most an individual can still do despite his or her limitations. 20 C.F.R. § 404.1545(a)(1). ... As already noted by the Court, the ALJ’s RFC determinations regarding plaintiff’s ability to sit, stand, walk, and use his right arm are supported by substantial evidence.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite her limitations.
Mallard v. Berryhill · filed 2020-03-23(a)(1)
A claimant’s RFC represents “the most [she] can still do despite [her] limitations.” 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a)(1) measures residual functional capacity by the most a claimant can do despite limitations.
Daniel v. Saul · filed 2020-03-23(a)(1)
An RFC assessment measures the most a person can do, despite his limitations. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... Consequently, the ALJ did not err in rejecting Plaintiff’s proposed occasional handling and fingering restriction on this basis.Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as what a claimant can do in a work setting despite limitations from medically determinable impairments.
Napieralski v. Commissioner of Social Security · filed 2020-03-24
RFC is a medical assessment of what an individual can do in a work setting in spite of functional limitations and environmental restrictions imposed by all of his medically determinable impairments. 20 C.F.R. § 404.1545. ... Given this limitation, the ALJ’s RFC determination that plaintiff could perform a range of light work after April 2015 is not supported by substantial evidence.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite the claimant’s limitations.
Price v. Social Security Administration, Commissioner of · filed 2020-03-25(a)(1)
An RFC is the most a claimant can do despite his limitations.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can still do despite limitations caused by impairments.
BUTTS v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-03-26(a)
“Residual functional capacity is defined as that which an individual is still able to do despite the limitations caused by his or her impairment(s).” Burnett v. Comm’r of Soc. Sec., 220 F.3d 112, 121 (3d Cir. 2000) (quoting Hartranft v. Apfel, 181 F.3d 358, 359 n.1 (3d Cir. 1999)); see 20 C.F.R. § 404.1545(a). ... Thus, the RFC assessment at step four was supported by substantial evidence.Read the full opinion on CourtListener →
An RFC assessment under section 404.1545 may account for memory and concentration impairments through work limitations supported by substantial evidence.
Maddalone v. Saul · filed 2020-03-27(a)(1)
Despite this, however, the ALJ did account for plaintiff’s reported memory and concentration problems by including reference to them in her RFC finding. The memory and concentration impairments were thus not ignored; rather the substantial evidence in the record as a whole supports the ALJ’s finding.Read the full opinion on CourtListener →
Section 404.1545(c) requires the ALJ to assess the nature and extent of a claimant’s mental limitations when formulating residual functional capacity.
Urlaub v. Commissioner of Social Security Administration · filed 2020-04-06(c)
The ALJ must “assess the nature and extent of a [claimant’s] mental limitations and restrictions” in formulating the RFC. 20 C.F.R. § 404.1545(c). However, the RFC need not contain a verbatim recitation of all limitations if the RFC otherwise incorporates them.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations and requires an assessment based on all relevant evidence.
Kozai v. Berryhill · filed 2020-04-06(a)(1)
The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... The ALJ’s RFC is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as an individual’s work-related abilities despite limitations.
Osborne v. Commissioner of Social Security · filed 2020-04-06(a)(1)
The RFC determination sets out an individual’s work-related abilities despite his or her limitations.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite limitations, assessed using all relevant evidence.
Ledesma v. Berryhill · filed 2020-04-07(a)(1)
The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... The ALJ’s RFC is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most work a claimant can do despite limitations caused by her impairments.
Caballero v. Commissioner of Social Security Administration · filed 2020-04-09(a)(1)
A claimant’s RFC is the most work she can do despite any limitations caused by her impairments. 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
Section 404.1545 does not require an RFC assessment to list a separate work restriction for every mental disorder.
McArdell v. Saul · filed 2020-04-23
The fact that the ALJ did not specifically address each of McArdell’s mental disorders in determining that she had the RFC to perform light work with exceptions and was limited to simple routine tasks, Admin. R. at 25-26, does not require reversal.Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can still do despite limitations, based on the evidence and limitations the ALJ finds credible.
Jones v. Berryhill · filed 2020-04-23(a)(1)
RFC is “the most [a claimant] can still do despite” his or her physical or mental limitations. 20 C.F.R. § 404.1545(a)(1). ... It is apparent that the ALJ conducted a detailed analysis of the objective evidence of record, and of Plaintiff’s testimony, and formulated a specific RFC that took into account all of Plaintiff’s limitations that the ALJ found credible and supported by the record.Read the full opinion on CourtListener →
An RFC assessment must account for supported limitations in concentration, persistence, and pace; a restriction to simple routine tasks does not adequately account for moderate limitations.
Petergal v. Saul · filed 2020-05-22(a)(1)
First, the restriction to “simple routine tasks” is not adequate to account for Plaintiff’s moderate limitations of concentration, persistence, or pace.Read the full opinion on CourtListener →
Section 404.1545 permits an RFC assessment to omit a separate restriction on interaction with supervisors when the medical opinions and other record evidence support that omission.
Meiers v. Commissioner of Social Security · filed 2020-05-28
The ALJ’s determination not to include any specific limitation in the RFC relating to Meiers’s ability to interact with supervisors (Tr. 20) is consistent with Juriga’s opinion, as well as other record evidence demonstrating that Meiers herself reported no difficulties following instructions or responding appropriately to those in authority (Tr. 204).Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC assessment to account for all of a claimant’s medically determinable impairments, including limitations in concentration, persistence, or pace.
Washington v. Commissioner of Social Security Administration · filed 2020-06-22(a)
However, in the absence of an explanation for such a conclusion, the undersigned is constrained to find the ALJ did not account for all of the claimant’s medically-determinable impairments as required pursuant to 20 C.F.R. § 404.1545(a).Read the full opinion on CourtListener →
An RFC assessment must account for limitations in responding to supervision; when it is unclear how an assessed work restriction accounts for a medical opinion finding a moderate limitation, the ALJ must explain the connection with specific evidence.
Gonzales v. Social Security Administration · filed 2020-08-05(c)
Moreover, because the connection between the medical sources’ finding of a “moderate” limitation in ability to interact with supervisors and the ALJ’s durational assessment of Mr. Gonzales to frequent interaction with supervisors is not obvious, the ALJ should have explained—with citation to specific evidence—how the work-related limitation he assessed accounted for the social-interaction limitation expressed in the medical opinions.Read the full opinion on CourtListener →
Section 404.1545(c) permits an RFC limited to simple, routine, and repetitive tasks to account for poor or limited memory.
Segobia, II v. Saul · filed 2020-08-10(c)
Though Plaintiff’s memory was noted as poor and limited at times, such limitations are adequately addressed by limiting tasks to simple, routine and repetitive.Read the full opinion on CourtListener →
An RFC assessment must address off-task time when the ALJ considers it in questioning a vocational expert, and must explain the conclusion reached.
Wagner v. Saul · filed 2020-08-18
Yet the ALJ included no off-task finding in the RFC, despite querying the VE about the same. ... This is error, as there is no logical bridge to follow to any conclusion about off-task time.Read the full opinion on CourtListener →
Section 404.1545(c) requires the ALJ to assess a claimant’s mental limitations and determine capacity for work on a regular and continuing basis.
Decker v. Commissioner of Social Security · filed 2020-09-25(c)
The ALJ must assess “the nature and extent of [a claimant’s] mental limitations and restrictions and then determine…[the] residual functional capacity for work activity on a regular and continuing basis.”Read the full opinion on CourtListener →
An ALJ’s lack of specificity about a mental impairment in an RFC assessment is harmless when substantial evidence shows that the impairment warrants no functional limitations.
Stefanescu v. Commissioner of Social Security · filed 2020-09-28(a)(2)
While the ALJ could have been more specific in his RFC analysis, see Parker-Grose v. Astrue, 462 F. App’x 16, 18 (2d Cir. 2012) (citing 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2)), his failure to do so was harmless because “substantial evidence supports his conclusion that [the plaintiff’s depression] did not warrant any limitations.” Sirris v. Comm’r of Soc. Sec., No. 18-CV-1087, 2020 WL 5105110, at *9 (W.D.N.Y. Aug. 31, 2020) (collecting cases); see also 20 C.F.R. §§ 404.1520a(c)-(d), 416.920a(c)-(d) (outlining the standards for evaluating mental impairments).Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider all relevant evidence and to explain whether a moderate limitation in interacting with others calls for restrictions on interactions with coworkers and supervisors.
Linares v. Saul · filed 2020-10-02(a)(1)-(2)
When determining a claimant's RFC, an ALJ must base his finding on all the relevant evidence in a claimant’s case record, including medical determinable impairments that are not deemed severe, 20 C.F.R. § 404.1545 (a)(1)-(2). ... Therefore, the Court agrees with Linares that the decision must be remanded to specifically address the question of whether Linares needs limitations in her interactions with supervisors and coworkers or provide an explanation for why that is not necessary, including citing to specific evidence in the record.Read the full opinion on CourtListener →
Section 404.1545(a) does not require an ALJ to include concentration, persistence, or pace limitations in an RFC when substantial evidence supports finding no such limitations.
EDELHEIT v. SAUL · filed 2020-10-20(a)
The ALJ set forth substantial evidence to find Edelheit suffered no limitations in concentration, persistence, and pace, and therefore was not required to include them in his vocational expert hypothetical or RFC.Read the full opinion on CourtListener →
An RFC may omit mental restrictions when substantial evidence shows that a non-severe mental impairment causes no more than mild functional limitations.
TUCKER v. SOCIAL SECURITY ADMINISTRATION · filed 2020-10-23(a)(1)
Based on this record–where Plaintiff’s non-severe adjustment disorder with depressed mood caused no more than mild limitations in her ability to function–the ALJ did not err in failing to include any mental limitation, including any limitation that may have been identified by Dr. Arrington, in the RFC determination.Read the full opinion on CourtListener →
An RFC need not include a specific neck movement restriction when the evidence does not show that the restriction would prevent the claimant from performing the assessed work.
Pinto v. Commissioner of Social Security · filed 2020-10-23
Finally, the Court finds no error in the ALJ’s decision not to incorporate neck limitations into the RFC. Indeed, although both Drs. Lorensen and Dreiner found that Plaintiff suffered from moderate limitations with regard to his neck movements, Plaintiff fails to provide any support for his claim that such impediments would prevent him from performing light work.Read the full opinion on CourtListener →
Section 404.1545(e) requires consideration of limitations caused by a mental impairment when assessing residual functional capacity, even if the impairment is not severe.
Jimenez v. Commissioner of Social Security · filed 2020-10-21(e)
Although the ALJ found that this impairment was not severe, and found that the impairment caused no more than mild limitations in the “paragraph B” criteria (id.), the ALJ was nonetheless required to consider any limitations caused by Plaintiff’s mental impairment when assessing Plaintiff’s RFC, and Dr. Parker’s opinion details limitations caused by that impairment. See 20 C.F.R. §§ 404.1545(e), 416.945(e).Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ to consider the functional limitations caused by medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.
REILLY v. SAUL · filed 2020-10-28(a)(2)
Regardless of the severity findings at step two, an ALJ must analyze what limitations the non-severe impairments cause in the context of the RFC assessment.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity must consider all impairments and how they relate to the medical evidence.
Williams v. Commissioner of Social Security · filed 2020-11-03(a)(2), (e)
In formulating a claimant’s RFC, the ALJ must consider all impairments and the extent to which they are consistent with medical evidence. 20 C.F.R. §§ 404.1545(a)(2), (e); 416.945(a)(2), (e).Read the full opinion on CourtListener →
Section 404.1545(c) requires the ALJ to assess a claimant’s mental limitations and determine the claimant’s capacity for work on a regular and continuing basis.
Clarke v. Saul · filed 2020-11-06(c)
In assessing the RFC, the ALJ “first assess[es] the nature and extent of [claimant’s] mental limitations and restrictions and then determine [claimant’s] residual functional capacity for work activity on a regular and continuing basis.” 20 C.F.R. § 404.1545(c).Read the full opinion on CourtListener →
An ALJ must explain what a production rate pace limitation means in the RFC assessment and connect it to the evidence.
Sutton v. Saul · filed 2020-11-09
Here, the ALJ failed to provide a definition, explanation, or anything else serving as a “logical bridge” to explain the meaning of his use of the term “production rate pace.” The term was not explained in the ALJ's RFC analysis, nor did the ALJ explain the term to the VE when posing the hypothetical containing the term.Read the full opinion on CourtListener →
An RFC assessment must incorporate a claimant’s supported moderate limitation in concentration, persistence, and pace.
Anderson v. Saul · filed 2020-11-20
Accordingly, on remand the ALJ shall ensure that Anderson’s moderate limitation in concentration, persistence, and pace is incorporated into the RFC assessment.Read the full opinion on CourtListener →
An RFC assessment may account for mild mental limitations when the ALJ performs a paragraph B analysis and indicates that the degree of limitation is reflected in the RFC.
Fambrini v. Saul · filed 2020-11-30(a)
However, the ALJ specifically indicated that the RFC finding reflects the degree of limitation the ALJ has found in the “paragraph B” mental function analysis. (AR 35.) “When an ALJ performs the Paragraph B analysis and indicates the ‘degree of limitation’ is incorporated into the RFC, this is sufficient to carry the burden imposed by the Regulations.” ... Given the evidence concerning Plaintiff’s abilities and activities identified by the ALJ’s opinion, the Court finds that the ALJ properly considered Plaintiff’s depression and did not err in his RFC assessment.Read the full opinion on CourtListener →
An RFC can account for moderate limits in concentration, persistence, or pace through restrictions on tasks, workplace changes, and social contact when the record supports those restrictions.
Pursell v. Saul · filed 2020-12-02(a)(1)
Based on the record here, Plaintiff’s limitations in concentration, persistence, or pace were not so significant that they required greater accommodations than those contained in the RFC.Read the full opinion on CourtListener →
An RFC assessment must account for credible limitations in mental work activities, including following instructions, responding to others, and handling work pressures.
Rieffer v. Saul · filed 2020-12-04(c)
The relevant mental work activities include understanding, remembering, and carrying out instructions; responding appropriately to supervision and co-workers; and handling work pressures in a work setting. 20 C.F.R. § 404.1545(c). ... The ALJ properly evaluated Plaintiff's subjective reports and included all of her credible limitations in the RFC determination.Read the full opinion on CourtListener →
Section 404.1545(e) makes evidence of mental limitations beyond those shown by psychological abnormalities relevant to residual functional capacity.
House Jr. v. Commissioner Social Security Administration · filed 2020-12-14(e)
However, Geers’ report is clearly probative, as it describes mental limitations “beyond that which can be determined on the basis of . . . psychological abnormalities alone.” 20 C.F.R. § 404.1545(e).Read the full opinion on CourtListener →
Omitting mental limitations from the written RFC assessment is harmless when the ALJ includes them in the vocational expert hypothetical and relies on the expert’s testimony at step five.
Barrett v. Saul · filed 2021-01-12
Because the ALJ included the mental limitations in the hypothetical to the VE, and relied on the VE’s testimony at step five, any failure to list the mental limitations in the RFC within the decision is harmless.Read the full opinion on CourtListener →
Section 404.1545(c) requires an RFC assessment to account for mental limitations that may reduce a claimant’s ability to work.
Strong v. Saul · filed 2021-02-02(c)
Mental limitations, as relevant here, must be part of the RFC assessment because “[a] limited ability to carry out certain mental activities, such as limitations in understanding, remembering, and carrying out instructions, and in responding appropriately to supervision, coworkers, and work pressures in a work setting, may reduce [a claimant's] ability to do past work and other work.” 20 C.F.R. § 404.1545(c).Read the full opinion on CourtListener →
Section 404.1545(c) requires assessment of mental limitations affecting a person’s ability to follow instructions and respond to supervision, coworkers, and work pressures.
Smith v. Saul · filed 2021-02-17(c)
When determining a person’s mental RFC, the ALJ is to “assess the nature and extent of your mental limitations and restrictions.” 20 C.F.R. § 404.1545(c). Mental limitations pertain to “understanding, remembering, and carrying out instructions, and in responding appropriately to supervision, co-workers, and work pressures in a work setting.” Id. Thus, Hollis’s opinion addressed the functions the ALJ was required to assess when determining Plaintiff’s mental RFC.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to assess work-related mental abilities and explain the resulting mental RFC sufficiently for judicial review.
Pohl v. Social Security Administration · filed 2021-03-11(c)
The ALJ offered no function by function assessment of Ms. Pohl’s mental RFC, and no explanation of which parts of Dr. Padilla’s opinion she credited and which she rejected. Because the ALJ’s reasons for the mental RFC are not articulated with sufficient particularity to allow for judicial review, the Court must remand.Read the full opinion on CourtListener →
Section 404.1545(c) treats the ability to handle work pressure as a mental work activity; limits on multitasking and production pace can account for mental limitations in an RFC.
Gibbs v. Saul · filed 2021-04-19(c)
The applicable regulations identify the ability to handle work pressure as a “mental activi[ty]” that affects an individual’s ability to work. 20 C.F.R. § 404.1545(c). An RFC that limits an individual to no multi-tasking and no fast-paced production rate work does address a claimant’s mental abilities.Read the full opinion on CourtListener →
An ALJ must consider all relevant evidence when assessing residual functional capacity and explain how that evidence supports the assigned work level.
Buncumb v. Commissioner of Social Security Administration · filed 2021-04-20(a)(3)
The court is constrained to agree that remand is required for the ALJ to explain how he concluded based on the evidence in the record that Plaintiff could perform medium work and could return to her past relevant work as a home health aide as it is generally performed.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite limitations and is assessed using all relevant evidence.
(SS) Rodriguez v. Commissioner of Social Security · filed 2021-04-21(a)(1)
The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a) assesses residual functional capacity from all relevant evidence as a claimant’s ability to sustain work despite impairments.
Guillory v. Commissioner of Social Security · filed 2021-04-23(a)
RFC is an assessment, based on all relevant evidence, of a claimant’s ability to do work on a sustained basis in an ordinary work setting despite his impairments.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite exertional and nonexertional limitations.
Eguren v. Saul · filed 2021-04-29(a)(1)
As noted above, an RFC is what a claimant can still do despite existing exertional and nonexertional limitations. See 20 C.F.R. §§ 404.1545(a)(1). ... The Court finds no error by the ALJ in considering the medical record in assessing Plaintiff’s RFC.Read the full opinion on CourtListener →
A residual functional capacity assessment can account for moderate limits in concentration, persistence, and pace through a supported restriction to two-hour periods of simple, routine work with limited decision making and changes in duties.
Funderburk v. Saul · filed 2021-04-30(a)(1)
The ALJ limited Plaintiff to an RFC of maintaining “concentration for up to two hours at a time to perform simple, routine tasks with only occasional decision making and occasional changes to the work duties,” which accounts for her limitations in concentration, persistence, and pace, which is supported by substantial evidence. (Tr. 20).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations, based on all relevant evidence.
(SS) Land v. Commissioner of Social Security · filed 2021-05-03(a)(1)
The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.”Read the full opinion on CourtListener →
Section 404.1545(a) authorizes and directs the ALJ to assess a claimant’s residual functional capacity.
Wainman v. Commissioner of Social Security · filed 2021-05-04(a)
The argument is not persuasive because the regulations authorize and direct the ALJ to assess a claimant’s RFC. 20 C.F.R. §§ 404.1545(a), and 404.1526(c); see also 404.1520b(c)(3) (determination of disability is an issue reserved to the Defendant Commissioner).Read the full opinion on CourtListener →
A claimant’s residual functional capacity is the most the claimant can do despite the claimant’s limitations.
PIOTROWSKI v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-05-07(a)(1)
A claimant’s RFC is the most that the claimant can do despite the claimant’s limitations. 20 C.F.R. § 404.1545(a)(1). ... In the view of this Court, this record contains substantial evidence to support the ALJ’s RFC determination.Read the full opinion on CourtListener →
Section 404.1545(a) requires the RFC assessment to consider relevant evidence and medically determinable impairments; a claimed need to elevate the legs may be omitted when substantial evidence supports that decision.
Thomas v. Commissioner of Social Security Administration · filed 2021-05-10(a)
He should consider all the relevant evidence and account for all the claimant’s medically-determinable impairments in the RFC assessment. 20 C.F.R. §§ 404.1545(a), 416.945(a). ... Given the foregoing, substantial evidence supports the ALJ’s decision not to include a provision in the RFC assessment for elevation of Plaintiffs bilateral lower extremities.Read the full opinion on CourtListener →
Residual functional capacity is what a claimant can still do despite exertional and nonexertional limitations.
Johnson v. Saul · filed 2021-05-12(a)(1)
As noted above, an RFC is what a claimant can still do despite existing exertional and nonexertional limitations. See 20 C.F.R. §§ 404.1545(a)(1).Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider relevant evidence of mental limitations; excluding those limitations requires adequate reasons for discounting a supporting medical opinion.
Nee v. Saul · filed 2021-04-26(a)(3)
The exclusion of mental functional limitations from the RFC assessment was undermined by the absence of specific and legitimate reasons based on substantial evidence to discount the examining psychologist’s opinion. Accordingly, reversal is warranted.Read the full opinion on CourtListener →
Section 404.1545(c) includes a claimant’s capacity for concentration, persistence, and pace in the assessment of mental residual functional capacity.
Mata v. Social Security Administration · filed 2021-05-21(c)
Mr. Mata’s capacity for concentration, persistence, or pace is part of his RFC.Read the full opinion on CourtListener →
Notes 3751–3900 of 6,798, oldest cases first.
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