Statute Annotations › Federal › 20 C.F.R. § 404.1545

20 C.F.R. § 404.1545

Residual functional capacity: the cases that interpreted this section

Jurisdiction
Federal
Case notes
6,798
Cited in passing
2,872
Citing cases indexed
11,963
Case dates
1981–2026
Screened through
2026-06-18
Checked for later law changes
2026-10-20
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

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

An ALJ may omit mental restrictions from a residual functional capacity finding when the decision as a whole sufficiently explains why the claimant’s mild mental limitations do not require them.

Jarnutowski v. Saul · filed 2021-06-01(a)(1)

When reading the ALJ’s decision as a whole, see Rice, 384 F.3d at 370 n.5, the extensive discussion at step two of Plaintiff’s mental health treatment records as well as her functional abilities is sufficient to trace the ALJ’s reasoning for declining to include mental limitations in the RFC finding.
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An RFC assessment must address an established limitation in interacting with supervisors separately from limitations involving coworkers and the public, or explain its omission.

CONKLIN v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-07-29(a)(1)

The ALJ’s failure to include a limitation relating to interaction with supervisors, and failure to explain why interaction with supervisors was apparently not limited despite the finding that Plaintiff is “moderately limited in interacting with others,” R. 28, cannot be viewed as harmless.
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An omitted supervisor-interaction limitation in an RFC assessment does not require remand when the jobs identified for the claimant require no more than occasional interaction with supervisors.

Maldonaldo v. Commissioner of Social Security · filed 2021-08-10(a)

In any event, any failure by the ALJ to include a specific limitation relating to plaintiff’s ability to interact with supervisors in the RFC was harmless because the positions identified by the vocational expert that plaintiff could perform do not require more than occasional interaction with supervisors.
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An RFC can accommodate moderate to marked stress limitations through restrictions on task complexity, workplace decisions, and interaction with others.

Wojtan v. Commissioner of Social Security · filed 2021-08-10

These limitations are entirely consistent with Ippolito’s assessment as they adequately accommodate a moderate to marked limitation in appropriately dealing with stress.
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Section 404.1545 requires an ALJ to explain the evidentiary basis for sit/stand and on-task limitations in a claimant’s residual functional capacity.

Magee v. Saul · filed 2021-08-11(a)(1)

A claimant’s RFC is the maximum work that he can perform despite any limitations. ... Here, the issue is not that the sit/stand limitation is vague, but that the basis (if any) for the on-task component was not articulated. Absent any explanation, the Court does not know how the ALJ arrived at this determination.
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Section 404.1545 does not require an additional RFC restriction for moderate limitations in concentration, persistence and pace when the ALJ explains, based on the medical evidence, why those limitations do not further restrict the claimant’s ability to work.

Gillespie v. Kijakazi · filed 2021-09-07(a)(1)

Because the ALJ’s close review of the medical record and discussion of Plaintiff's limitations properly explained why the ALJ’s findings regarding Plaintiff's moderate limitations in concentration, persistence and pace did not translate into further RFC limitations, Mascio does not warrant remand in this case.
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An RFC assessment must account for limitations caused by episodic bipolar disorder; mental restrictions supported by substantial evidence can satisfy that requirement.

Nixon v. Commissioner of Social Security · filed 2021-09-13(a)(1)

The ALJ’s Decision here differs from those in Schink and Samuels in that it reflects careful consideration of Plaintiff’s bipolar disorder, acknowledges its episodic nature, and accounts for mental limitations in the RFC.
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Section 404.1545(a)(1) requires an RFC assessment based on all relevant record evidence, including limitations arising from mental impairments.

MOUSER v. KIJAKAZI · filed 2021-09-17(a)(1)

When crafting a claimant's mental RFC, "the ALJ must evaluate all limitations that arise from medically determinable impairments, even those that are not severe." Villano, 556 F.3d at 563; see 20 C.F.R. § 404.1545(a)(1) ("We will assess your residual functional capacity based on all relevant evidence in your case record."); ... In this case, the ALJ concluded that Kelli has a mild limitation in interacting with others, included no non-exertional limitations in the RFC that would address this limitation, and provided no explanation as to why no limitations were included in the RFC.
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An RFC limiting a claimant to simple, routine and repetitive tasks can adequately account for a moderate limitation in concentration, persistence, or pace.

Kohlbusch v. Kijakazi · filed 2021-09-17

Like in Chismarich, 888 F.3d at 980, Kohlbusch’s moderate limitation in the area of concentration, persistence, or pace is adequately reflected in the RFC limitation to “simple, routine and repetitive tasks.”
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Section 404.1545 requires an RFC assessment to account for supported mental limitations, including limitations in work pace.

Simonet v. Kijakazi · filed 2021-09-30(a)(1)

But even if she was not endorsing Dr. Kores’ findings, the ALJ’s RFC determination does not account for all of the limitations she found. In particular, there is no limitation corresponding to the moderate limitation that Dr. Jennings found in Plaintiff’s ability to maintain pace in a work setting.
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Section 404.1545 requires an RFC assessment to account for a claimant’s mental limitations and explain how those limitations affect the work the claimant can still do.

Kempton v. Saul · filed 2021-11-10

Here, the ALJ failed to conduct a function-by-function analysis of the Plaintiff’s mental health limitations and work-related abilities prior to expressing his RFC assessment.
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An RFC must include limitations supported by substantial evidence, but need not include alleged limitations the ALJ reasonably discredits.

Gray v. Commissioner Social Security Administration · filed 2021-11-15(a)

The ALJ is required to include only those limitations that are supported by substantial evidence in the RFC and, by extension, hypothetical questions posed to the VE.
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Section 404.1545(a)(1) requires an RFC assessment to consider the functional limitations resulting from a claimant’s conditions.

Patterson v. Commissioner of the Social Security Administration · filed 2021-11-18(a)(1)

But “[t]he ALJ need only consider the resultant functional limitations arising from [Plaintiff’s] conditions, if any, to formulate [the] RFC.” Corber v. Massanari, 20 F. App’x 816, 822 (10th Cir. 2001); see also 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1) (defining RFC).
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Section 404.1545 requires an RFC assessment to account for supported functional limitations, including limitations on the tasks a claimant can perform.

(SS) Priestley v. Commissioner of Social Security · filed 2021-11-29(a)

Because the ALJ did not identify any reason for rejecting a limitation to “one and two step tasks” when formulating the RFC, the ALJ failed to carry the burden to properly address the medical opinions.
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Residual functional capacity is the most work a claimant can perform despite limitations; medical opinions can support an RFC restriction to simple, routine, repetitive tasks for moderate difficulties with concentration, persistence, or pace.

Edenhofer v. Saul · filed 2021-11-12(a)(1)

A claimant’s RFC is the maximum work that she can perform despite any limitations. ... As such, the doctors’ RFC opinions and accompanying explanations support the ALJ’s decision to limit Plaintiff to simple, routine, and repetitive tasks to accommodate her moderate deficiencies of concentration, persistence, or pace.
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An ALJ must account for relevant symptoms when determining residual functional capacity, even if the ALJ did not identify them as separate severe impairments at step two.

Thompson v. Kijakazi · filed 2021-11-12(a)(1)

And it is well settled that any error associated with an ALJ’s failure to identify a given impairment at step two will be harmless, so long as the ALJ weighs the relevant symptoms appropriately in formulating the RFC determination. ... The ALJ thus committed no legal error in taking account of Plaintiff’s cognitive and memory issues.
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Section 404.1545(a) defines residual functional capacity as the most a claimant can still do in a work setting despite her limitations.

Williams v. SAUL · filed 2021-11-12(a)

A claimant’s RFC reflects “the most [she] can still do [in a work setting] despite [her] limitations.” 20 C.F.R. §§ 404.1545(a), 416.945(a).
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Section 404.1545(a)(3) assigns the claimant responsibility for providing evidence of an impairment and its severity, and the ALJ responsibility for resolving evidentiary conflicts and determining residual functional capacity.

Pena-Maldonado v. Commissioner of Social Security · filed 2021-11-15(a)(3)

A claimant is responsible for providing the evidence of an impairment and its severity; the ALJ is responsible for resolving any evidentiary conflicts and determining the claimant’s RFC.
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An ALJ must address a moderate mental limitation in the residual functional capacity assessment or explain why it was omitted.

Dean v. Kijakazi · filed 2021-11-16(a)

However, it is not a “categorical rule” that the ALJ must always include the moderate limitation in an RFC; instead, the ALJ must only address the mental limitations in the RFC or provide an explanation for omitting it.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite impairments.

Johnson v. Social Security Administration, Commissioner of · filed 2021-11-17(a)(1)

A claimant’s RFC is the most the claimant can do despite his or her impairments. 20 C.F.R. §§ 404.1545(a)(1); 416.945(a)(2).
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Section 404.1545 permits an ALJ to express a claimant’s exertional abilities by referring to a defined work category such as light work.

Furman v. Commissioner of Social Security · filed 2021-11-30

As in Terry, the Court finds that the ALJ’s reference to “light work” as defined in the regulations adequately defines Plaintiff’s exertional abilities, given that SSR 83-10 defines “light work” to require standing/walking off and on for approximately six hours per workday, with intermittent sitting for the remainder of the workday.
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Section 404.1545 directs ALJs assessing residual functional capacity to consider a claimant’s physical and mental abilities, sensory requirements, and other functions.

Athanas v. Commissioner of Social Security Administration · filed 2021-11-30(b)–(d)

The ALJ should consider a claimant’s ability to meet physical and mental demands, sensory requirements, and other functions.
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Section 404.1545(a)(1) permits an RFC assessment to omit mild mental limitations when the ALJ finds they do not affect what the claimant can do in a work setting.

Sepulveda v. Commissioner of Social Security · filed 2022-02-03(a)(1)

Accordingly, the ALJ properly considered Plaintiff’s mental limitations and determined that those did not affect what she could do in a work setting. See 20 C.F.R. § 404.1545(a)(1).
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Section 404.1545(c) requires an RFC assessment to account for mental limitations or explain why no further limitation is warranted.

Genie v. Kijakazi · filed 2022-02-09(c)

Although the ALJ found that Plaintiff had moderate limitations in her ability to maintain concentration, persistence, or pace, see AR 22, he did not include additional limitations in the RFC to account adequately for the particular mental limitations, or, in the alternative, explain the decision not to limit Plaintiffs RFC further.
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An RFC assessment must account for mild mental impairments or explain why they require no functional limitation.

Anderson v. Commissioner of Social Security Administration · filed 2022-02-09(a)(2)

On the facts presented here, the court finds that the ALJ erred when he omitted from his RFC assessment a limitation that reflects his finding of Plaintiff’s mild mental impairments and failed to state why any such limitation is not necessary.
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An RFC assessment must address how the claimant’s functional limitations reflected in the paragraph B findings are accounted for, or explain why additional limitations are unwarranted.

SERVEDIO v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-02-24

On remand, the ALJ shall explain whether or not additional limitations are warranted in the RFC assessment in light of her findings regarding the four broad areas of functioning as measured by the “paragraph B” criteria.
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An RFC may omit mild mental limitations when the ALJ considers them and substantial evidence supports the resulting RFC.

Lindell v. Kijakazi · filed 2022-03-18(a)(1)

In sum, because the ALJ considered Plaintiff’s mild mental health limitations in determining the RFC and because the record as a whole supports the RFC, the ALJ did not err in omitting mild mental limitations from the RFC.
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Section 404.1545 requires an RFC assessment to address any restrictions needed to account for moderate limitations in concentration, persistence, or pace.

Kwasniewski v. Kijakazi · filed 2022-03-31

But in reaching that decision the ALJ must, as the Commissioner notes, “reevaluate [Kwasniewski’s] residual functional capacity, including any restrictions to account for her moderate limitations in concentration, persistence, or pace; reweigh the medical opinion evidence, including Dr. Paquette’s opinion, as well as the opinions of state agency reviewing psychologists Roger Rattan, Ph.D., and Jack Spear, Ph.D.”
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations.

Keck v. O'Malley · filed 2022-03-31(a)(1)

A claimant’s RFC is “the most [the claimant] can still do despite [the claimant’s] limitations.” 20 C.F.R. § 404.1545(a)(1). ... The ALJ reasonably accounted for Keck’s CPP limitations in the RFC and hypothetical question. He provided an accurate and logical bridge from the evidence to his conclusions, and substantial evidence supports the ALJ’s RFC assessment.
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Section 404.1545(a) requires residual functional capacity to be assessed from all relevant medical and other evidence of what a claimant can still do despite impairments.

Wright v. Kijakazi (CONSENT) · filed 2022-03-31(a)

An RFC determination is an assessment of what a claimant is still able to do despite the claimant’s impairments and is based on all relevant medical and other evidence.
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Section 404.1545 measures residual functional capacity by what a claimant can do despite credible limitations.

Courtney v. Kijakazi · filed 2022-03-31

Residual functional capacity is a measure of what a claimant can do despite her credible limitations. See 20 C.F.R. § 404.1545. ... Having reviewed the record at length, the Court finds that the ALJ has done so here.
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Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider all relevant evidence of the claimant’s impairments and related symptoms.

MacDonald v. Kijakazi · filed 2022-03-31(a)

In making the RFC assessment, the ALJ must consider all relevant evidence of the claimant’s impairments and any related symptoms. See 20 C.F.R. § 404.1545(a).
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite his limitations.

Porter v. Kijakazi · filed 2022-03-31(a)(1)

A claimant’s “residual functional capacity is the most he can do despite his limitations.”
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Residual functional capacity is the most a claimant can do despite limitations, and the assessment must be supported by substantial evidence.

Hill v. Kijakazi · filed 2022-03-31(a)(1)

A claimant’s RFC is “the most a claimant can do despite [the claimant’s] limitations.” ... For all of the above reasons, the Court finds that the ALJ’s RFC assessment was supported by substantial evidence.
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Section 404.1545 requires an RFC assessment supported by evidence of the claimant’s ability to perform relevant work functions, including standing and walking.

Gray v. Saul · filed 2022-03-31(a)(1)

The ALJ failed, however, to provide any specific assessment of Ms. Gray’s ability to perform the walking and standing requirements of light work. Indeed, the Record contains no medical source statement or other RFC assessment explicitly indicating that Ms. Gray can stand or walk for six hours. The lack of medical evidence reflecting Ms. Gray’s ability to perform light work prevents the Court from performing meaningful review of the ALJ’s RFC determination, and remand for further development of the Record is therefore warranted.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations, based on all relevant record evidence.

Gasperini v. Commissioner of Social Security · filed 2022-03-31(a)(1)

For the reasons set forth below, the Court agrees with the Commissioner and finds that the ALJ’s RFC determination is supported by substantial evidence. ... The RFC determination represents “the most [a claimant] can still do despite [his] limitations,” based on all the relevant evidence in the record. 20 C.F.R. § 404.1545(a)(1).
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Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite her limitations.

Clayton v. Commissioner of the Social Security Administration · filed 2022-03-31(a)

A plaintiff’s residual functional capacity (“RFC”) “is the most [she] can still do despite [her] limitations.” 20 C.F.R. § 404.1545(a). ... The Court holds that the RFC determination is supported by substantial evidence and that, contrary to Plaintiff’s assertions, the ALJ properly weighed the medical opinion evidence and properly evaluated her physical and mental impairments—including subjective statements—in formulating a RFC.
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Section 404.1545(a)(1) requires an RFC assessment to consider all relevant evidence in determining what a claimant can still do despite impairments.

Steele v. Commissioner Social Security Administration · filed 2022-03-31(a)(1)

Plaintiff's RFC is the most she can still do despite her impairments and is determined by “assessing all relevant evidence. 20 C.F.R. § 404.1545(a)(1). ... The ALJ was not unreasonable in concluding that Plaintiffs significant, if temporary, improvement with treatments was contradictory to the assessment of Dr. Ramirez that she would be off-task 70% of the time and must lie down for three to four hours in an eight-hour day.
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An ALJ assessing residual functional capacity may find a medical opinion persuasive without adopting every limitation it identifies, after reviewing the medical record and other opinions.

BRUCE v. SAUL · filed 2022-03-31(a)(3)

However, simply finding an opinion persuasive does not mean that the ALJ must accept the persuasive medical opinion wholesale.
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Section 404.1545 requires an ALJ to consider all relevant evidence and account for the claimant’s limitations when assessing residual functional capacity.

Roybal v. Commissioner Social Security Administration · filed 2022-04-08

The residual functional capacity (RFC) is the most a person can do, despite his physical or mental limitations. 20 C.F.R. §§ 404.1545, 416.945. ... Because the ALJ erred in rejecting the testimony of Plaintiff and Martha H. and the medical opinion of Dr. Rozell, the ALJ’s RFC was deficient and did not incorporate all of Plaintiff’s limitations.
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Section 404.1545 defines residual functional capacity as the most a claimant can do despite their limitations.

Leitz v. Kijakazi · filed 2022-04-11

An RFC is an assessment regarding the most a claimant is capable of despite their limitations. 20 C.F.R. §§ 404.1545, 416.945.
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An RFC assessment need not add limitations for agoraphobia when the existing restrictions account for its supported effects.

Jones v. Saul · filed 2022-04-05(a)(1)

The ALJ did not err in declining to include additional RFC limitations specific to Plaintiff's agoraphobia.
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Section 404.1545(a) requires consideration of mental limitations in assessing residual functional capacity; an ALJ need not repeat an analysis already given elsewhere in the decision.

Clark v. Commissioner of Social Security · filed 2022-04-13(a)

The ALJ was not required to restate this determination later in her decision; therefore, even though it was not discussed as part of the Consistency analysis of her RFC determination, the ALJ sufficiently addressed the issue.
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An RFC assessment must account for mental limitations in an opinion the ALJ finds persuasive or explain their omission.

Thompson v. Commissioner of Social Security · filed 2022-04-20

As to Dr. Salandy, the ALJ found the opinion “persuasive,” Tr. at 22, but did not include all of the limitations that Dr. Salandy assigned.
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An RFC assessment must account for a supported functional limitation or explain why the medical opinions supporting it were rejected.

Edgell v. Social Security Administration · filed 2022-06-06(a)(1)

First, the ALJ erred by failing to either: (a) account, in the assigned RFC, for a moderate functional limitation arising from Mr. Edgell’s severe mental impairments, despite giving great or significant weight to two medical source opinions supporting the limitation; or, (b) explain why she rejected the medical source opinions at issue.
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Section 404.1545 requires the RFC assessment to consider all work-related limitations, including limitations from non-severe impairments.

Fiederowicz v. Commissioner Social Security Administration · filed 2022-06-06(a)

The RFC represents all of a claimant's work-related limitations, including non-severe limitations. 20 C.F.R. §§ 404.1545(a)(1–2); 416.945(a)(1–2). ... Accordingly, the ALJ failed to properly consider Plaintiff’s alleged limitations related to her convergence insufficiency when proceeding through the steps of the sequential evaluation.
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Section 404.1545 requires the ALJ to assess a claimant’s mental limitations when determining the claimant’s capacity for work on a regular and continuing basis.

MAKANDA v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-06-30(c)

When determining a claimant’s RFC, the ALJ must assess “the nature and extent” of a claimant’s mental and/or physical limitations “and then determine [that claimant’s RFC] for work activity on a regular and continuing basis.”
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An RFC assessment must account for a marked limitation in interacting with others; a restriction to occasional interaction does not sufficiently reflect that limitation.

Roadcap v. Social Security Administration · filed 2022-07-01(a)(2)

An RFC restriction to occasional conduct does not sufficiently reflect a marked limitation in the ability to interact with others.
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An RFC assessment need not include additional physical limitations that the record does not credibly support.

LATHM v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-07-05

On this record, the ALJ was entitled to find that additional physical limitations are not credibly supported and she properly excluded them from the RFC.
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Section 404.1545(a)(1) requires an RFC to include mental limitations that affect what a claimant can do in a work setting; mild limitations that do not prevent basic work activities need not be included.

Freeman v. SSA · filed 2022-07-06(a)(1)

The ultimate RFC only includes “mental limitations that affect what [the claimant] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1). As Plaintiff’s mild limitations “do not prevent [her] from performing basic work activities,” there was no reason that the ALJ was required to incorporate the mental limitations in Plaintiff’s RFC.
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Section 404.1545(c) does not list interaction with the general public among the mental abilities assessed in a residual functional capacity.

Perea v. Social Security Administration · filed 2022-08-02(c)

Plaintiff also focuses on the limitation relating to interaction with the general public, but SSR 96-8p does not include “ability to interact with the general public” as a skill required for all work and thus one that must be included in the function-by-function analysis. See also 20 C.F.R. §§ 416.945(c), 404.1545(c) (listing what will be assessed in mental abilities in the RFC—a list that does not include any mention of interaction with the general public); Nelson v. Colvin, 655 F. App’x 626, 629 (10th Cir. 2016) (“unskilled work does not require” the ability to “interact appropriately with the public”).
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An RFC may account for moderate limitations in concentration, persistence, or pace by limiting the claimant to unskilled work when the record supports that limitation.

Dominguez v. Social Security Administration · filed 2022-08-05(a)(2)

The Court, therefore, is satisfied that the ALJ adequately accounted for Plaintiff’s moderate limitation in concentrating, persisting, or maintaining pace by limiting her to unskilled work.
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An RFC assessment must address whether mild mental limitations affect a claimant’s ability to work.

Perry v. Commissioner of Social Security · filed 2022-08-08(a)

Here, the ALJ sufficiently addressed whether Plaintiff’s mild limitations affected her RFC.
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An RFC assessment must consider a claimant’s mental limitations, even when the ALJ finds the underlying impairment non-severe.

Smith v. Commissioner of Social Security · filed 2022-08-25

Because the ALJ did not further consider Petitioner’s mental limitations when crafting the RFC, these errors cannot be deemed harmless.
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An RFC assessment need not include a mild mental limitation when it causes no work limitation.

Finley v. Commissioner of Social Security · filed 2022-09-01(a)(2), (e)

However, an RFC assessment or hypothetical question posed to a vocational expert need not include a mild mental limitation where there is no work limitation.
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Mild limitations under the paragraph B criteria do not, by themselves, require mental limitations in the residual functional capacity assessment.

Harris v. Commissioner Social Security · filed 2022-09-06

The ALJ did not err in failing to include any mental limitations in the RFC assessment, despite finding that Plaintiff had mild limitations in the four broad functional areas of the PRT.
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Section 404.1545(c) requires an RFC assessment to account for supported mental limitations that may reduce a claimant’s ability to do past or other work.

Bezane v. Saul · filed 2022-09-06(c)

This includes mental limitations, as “‘[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.’” Craft, 539 F.3d at 676 (quoting 20 C.F.R. § 404.1545(c)).
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Section 404.1545(c) calls for assessing a claimant’s mental limitations before determining her capacity for regular, continuing work.

DEANGELO v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-08-25(c)

When assessing mental abilities, the nature and extent of the claimant’s mental limitations and restrictions is assessed first and is followed by a determination of her residual functional capacity for work activity on a regular and continuing basis. 20 C.F.R. § 404.1545(c). ... In view of the record as a whole, there is substantial evidence supporting the ALJ’s mental RFC determination.
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An omission of limitations from a residual functional capacity assessment is harmless when including them would not change the disability decision.

Johnson v. Kijakazi · filed 2022-08-26

Even assuming that the ALJ erred by failing to include limitations to “routine and simple instructions” and “unskilled work” in the residual functional capacity, any error was harmless because there is no indication that the ALJ would have decided differently if he had, in fact, included those limitations in his residual functional capacity.
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Section 404.1545(a)(3) requires the ALJ to consider all relevant evidence when assessing residual functional capacity, including medical opinions from treating, examining, and non-examining sources.

Avalos v. Commissioner of Social Security · filed 2022-08-30(a)(3)

In determining a claimant’s RFC, the ALJ must consider all relevant evidence, including the medical opinions of treating, examining and non-examining medical sources, as well as the opinions of other sources.
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Section 404.1545(a)(3) bases residual functional capacity on medical evidence and other evidence about what a claimant can still do.

Ragland v. Commissioner of Social Security · filed 2022-08-30(a)(3)

The RFC is based upon medical evidence—including statements from medical sources about what the claimant still can do—as well as “other evidence, such as testimony by the claimant or his friends and family.” Craft v. Astrue, 539 F.3d 668, 676 (7th Cir. 2008); 20 C.F.R. § 404.1545(a)(3).
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An ALJ assessing residual functional capacity need not discuss every reported daily-living difficulty when the decision shows that the ALJ considered the claimant’s testimony.

Selph v. Social Security Administration · filed 2022-08-30(a)(3)

That the ALJ considered Plaintiff’s self-described limitations is evident through the ALJ’s citation to Plaintiff’s testimony. AR 91. That the ALJ did not explicitly reference each and every difficulty Plaintiff reported he has in taking care of himself is not error.
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Section 404.1545(a) measures residual functional capacity by the most activity a claimant can perform despite his limitations.

KITT v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-08-31(a)

An RFC should account for the most activity that a claimant can perform despite his limitations. 20 C.F.R. § 404.1545(a). ... Viewing the ALJ’s decision and the record as a whole, the Court concludes that the ALJ provided substantial evidence to support the RFC determination.
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An RFC finding may account for moderate limits on repetitive lifting and carrying of heavy objects when the record supports the claimant’s remaining work capacity.

Tagliarino v. Commissioner of Social Security · filed 2022-08-31

As an initial matter, I disagree with plaintiff that the moderate limitations Brauer assessed are necessarily inconsistent with the lifting and carrying requirements of medium work. ... In sum, I find that ALJ adequately explained why his RFC findings were supported by record evidence, including Brauer’s opinion that plaintiff had moderate limitations for activities involving repetitive lifting and carrying of heavy objects, and conclude that his determination is supported by substantial evidence in the record.
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An RFC assessment must be based on all relevant evidence in the claimant’s case record.

Schnarre v. Saul · filed 2022-09-01(a)

A claimant’s RFC is “the most [the claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a). The assessment of a claimant’s RFC must be “based on all the relevant evidence in [the claimant’s] case record.” Id.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.

Lovett v. Saul · filed 2022-09-01(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). ... Under these circumstances, the undersigned is not left to guess as to the basis for the ALJ’s findings and concludes that the ALJ supported his decisions regarding Plaintiff’s RFC with substantial evidence.
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Section 404.1545 defines residual functional capacity as the ability to sustain physical and mental work activities despite limitations from impairments.

Despres v. Saul · filed 2022-09-02

An individual’s RFC is her ability to do physical and mental work activities on a sustained basis despite limitations from her impairments. 20 C.F.R. §§ 404.1545, 416.945.
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An ALJ’s residual functional capacity finding must have some medical evidence supporting it, but it need not be supported by a specific medical opinion.

Kelly v. Kijakazi · filed 2022-09-02(a)

Although there must be some medical evidence supporting the ALJ’s RFC finding, there is no requirement that the evidence take the form of a medical opinion.
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Section 404.1545 requires residual functional capacity to be assessed from all relevant evidence about what a claimant can still do despite her limitations.

DAVIS v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-09-06

A claimant’s residual functional capacity is the most she can do despite her limitations and is based on all the relevant evidence in the case record, including her medical history, medical signs and laboratory findings, the effects of treatment, daily activities, recorded observations, and any medical source statements.
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Section 404.1545 defines residual functional capacity as the ability to perform physical and mental work activities on a sustained basis despite limitations from impairments.

Bloodmoon v. Saul · filed 2022-09-06

An individual’s RFC is her ability to do physical and mental work activities on a sustained basis despite limitations from her impairments.
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Section 404.1545(a) requires an ALJ to assess residual functional capacity using all relevant, credible evidence, including medical records, treating physicians’ observations, and the claimant’s descriptions of symptoms and limitations.

Ryherd v. Kijakazi · filed 2022-09-06(a)

The ALJ bears the primary responsibility for assessing a claimant’s RFC based on all relevant, credible evidence in the record, including medical records, the observations of treating physicians and others, and the claimant’s own description of her symptoms and limitations. ... The ALJ thoroughly discussed specific medical facts, nonmedical evidence, and the consistency of such evidence when viewed in light of the record as a whole, and she assessed Ryherd’s RFC based on the relevant, credible evidence of record.
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An ALJ must base a claimant’s residual functional capacity on all relevant evidence, including medical records, medical opinions, and the claimant’s descriptions of her limitations.

Rosario-Torres v. Commissioner of Social Security · filed 2022-09-06(a)(3)

When formulating a claimant’s RFC, the ALJ must base his determination on all relevant evidence, including a claimant’s medical record, the medical opinions, and a claimant’s descriptions of her limitations. 20 C.F.R. §§ 404.1545, 404.1546.
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Section 404.1545(c) includes understanding and following instructions, responding to supervisors and co-workers, and handling work pressures among the mental activities relevant to residual functional capacity.

Burke v. Saul · filed 2022-09-12(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).
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Section 404.1545(a) requires an ALJ to consider mild mental limitations when assessing residual functional capacity and explain why they do not warrant work restrictions.

SMITH v. KIJAKAZI · filed 2022-09-15(a)

Because the Court is unable to trace the ALJ's reasoning to determine whether the ALJ has provided a logical bridge from the evidence to her conclusion, remand is required. On remand, the ALJ must either incorporate into the RFC non-exertional limitations that account for Barbara's mild mental limitations in the "paragraph B" criteria or explain why such limitations are unnecessary.
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Section 404.1545 does not require an ALJ to include off-task or absenteeism limitations in a claimant’s residual functional capacity when the record does not support them.

Bayless-Skeens v. Commissioner of Social Security · filed 2022-09-15(a)(1)

Accordingly, substantial evidence supports the ALJ’s RFC, and the ALJ did not err by failing to include additional limitations for off-task behavior and absenteeism.
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Residual functional capacity assesses what a claimant can do at work despite limitations from all medically determinable impairments; an assessment of mental limitations must be supported by a meaningful review of the relevant evidence.

Hoezee v. Commissioner of Social Security · filed 2022-09-29

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 her medically determinable impairments. 20 C.F.R. § 404.1545. ... These conclusory findings with respect to plaintiff’s sporadic employment and mental stability are not supported by substantial evidence. Specifically, the ALJ’s decision does not address plaintiff’s employment history, treatment, hospitalization, or episodes of self harm in any detail.
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Section 404.1545(a)(1) requires an RFC assessment to account for moderate limitations in concentration, persistence, and pace; limits on workplace changes and interactions can suffice when supported by the record.

Neale v. Kijakazi · filed 2022-10-07(a)(1)

On this record, the ALJ’s hypothetical and RFC analysis limiting Plaintiff to occasional changes in the workplace and occasional interaction with coworkers and supervisors is supported by substantial evidence and adequately accounts for Plaintiff's moderate limitations in concentration, persistence, and pace.
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A mental RFC is sufficient when the ALJ gives a valid explanation grounded in the evidence; no particular wording is required.

Drozd v. Kijakazi · filed 2023-01-06

Instead, the evaluation of a claimant’s ability to undertake the mental demands of the workplace will be viewed in the factual context of the case, and a mental RFC is sufficient if it is supported by a valid explanation grounded in the evidence.
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An ALJ may account for moderate limitations in concentration, persistence, or pace by restricting a claimant to simple, routine, repetitive tasks when the RFC assessment adequately explains why that restriction accounts for those limitations.

Cote v. Commissioner of Social Security · filed 2023-03-01(a)(4)

As in Shinaberry, the ALJ adequately addressed the Claimant’s ability to concentrate, persist, or maintain pace in the RFC and explained why a restriction to simple, routine, repetitive tasks sufficiently accounts for Claimant’s moderate limitations in those areas.
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Mild limitations in the paragraph B criteria do not automatically require mental limitations in the residual functional capacity.

Guerrera v. Commissioner of Social Security · filed 2023-03-10(e)

Additionally, the persuasive precedent demonstrates that ALJs are not obligated to include mental limitations in the RFC even when they find “mild” limitations in the paragraph B criteria.
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Section 404.1545 requires an RFC to account for functional limitations supported by the evidence, including mental limitations.

Austin v. Commissioner of Social Security · filed 2023-03-13(a)(1)

Here, the ALJ addressed all those functions implicated by the evidence and supported his conclusions with citations to that evidence. ... Thus, the RFC adequately accounts for Mr. A.’s demonstrated limitations.
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An RFC must account for supported moderate mental limitations when the ALJ gives significant weight to the opinions describing them, or explain why those opinions were rejected.

Kantor v. Social Security Administration · filed 2023-03-16(a)(1)

For the reasons discussed below, the Court agrees with Mr. Kantor that ALJ Richter erred at step four by failing to either: (a) account, in the RFC, for moderate limitations arising from Mr. Kantor’s mental impairments, despite giving significant weight to medical source opinions supporting the limitations; or (b) explain why she rejected the medical source opinions at issue.
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Section 404.1545 does not require an ALJ to include mental limitations in the RFC solely because the claimant has mild limitations under the paragraph B criteria.

Alvarado v. Kijakazi · filed 2023-03-17

In sum, the ALJ did consider Alvarado’s mild mental limitations in her RFC assessment—even though she didn’t have to.
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An RFC assessment must explain how the evidence supports a concentration limit when the claimant has moderate limitations in concentration, persistence, and pace.

BOYER v. KIJAKAZI · filed 2023-03-21

In summary, because the ALJ did not create the requisite logical bridge between the evidence and the RFC for Stephanie B.'s moderate CPP limitation, remand is required.
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Section 404.1545(a)(1) requires consideration of social functioning when determining residual functional capacity, but an adequately considered limitation need not be expressly included in the RFC.

Dawn v. Kijakazi · filed 2023-03-14(a)(1)

The Court is satisfied that the ALJ adequately considered Plaintiff’s social functioning, even if not expressly included in the RFC.
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Section 404.1545(c) requires an assessment of mental residual functional capacity to account for the nature and extent of a claimant’s mental limitations, including limits on following instructions and responding to people and work pressures.

Miller v. Kijakazi · filed 2023-03-24(c)

A claimant’s mental RFC must account for “the nature and extent of [the claimant’s] mental limitations and restrictions,” including “limitations in understanding, remembering, and carrying out instructions, and in responding appropriately to supervision, co-workers, and work pressures in a work setting.” 20 C.F.R. §§ 404.1545(c), 416.945(c).
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Section 404.1545(a)(1) defines residual functional capacity as the most work a claimant can perform despite his limitations.

Ritchie v. Kijakazi · filed 2023-03-27(a)(1)

A claimant’s RFC is the maximum work that he can perform despite any limitations. 20 C.F.R. § 404.1545(a)(1); SSR 96-8p.
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Section 404.1545 measures residual functional capacity by what a claimant can do regularly despite supported limitations.

Ayers v. Kijakazi · filed 2023-03-28(a)

RFC is a measure of the most a claimant can do on a regular and recurring basis despite credible and supported limitations. See 20 C.F.R. § 404.1545.
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Section 404.1545(a) requires an ALJ to assess what a claimant can still do in light of both physical and mental limitations.

(SS) MacLellan v. Commissioner of Social Security · filed 2023-03-28(a)

In determining residual functional capacity, the ALJ must assess what the plaintiff can still do in light of both physical and mental limitations.
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Section 404.1545(a) defines residual functional capacity as the most a claimant can do in a work setting despite physical or mental limitations.

Davidson v. Commissioner, Social Security Administration · filed 2023-03-28(a)

Residual functional capacity is an assessment of the most that a claimant can do in a work setting, despite the claimant’s mental and/or physical limitations. 20 C.F.R. §§ 404.1545(a), 416.945(a). ... In this case, the ALJ properly exercised his responsibility as fact finder to analyze the evidence, and his determination of Plaintiff's RFC is well-grounded in that analysis.
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An ALJ assessing residual functional capacity may reject a claimed need for a cane after considering the claimant’s testimony and explaining why the medical evidence does not support that need.

Love v. Commissioner of Social Security · filed 2023-03-28

The ALJ, then, did not ignore Love’s hearing testimony about her cane use in the RFC assessment. Rather, she explained why the most recent medical evidence in the record did not support the testimony. She placed greater weight on the medical evaluations conducted most recently, so her finding was supported by substantial evidence in the record. She also adequately explained the conclusions she drew from this evidence.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.

Simmons v. Kijakazi · filed 2023-03-28(a)(1)

A claimant’s RFC is the most he or she can do despite his or her limitations. 20 C.F.R. § 404.1545(a)(1). ... Considering the ALJ’s detailed analysis of Plaintiff’s medical history, the relevant medical opinions, Plaintiff’s testimony, and her activities of daily living, this Court concludes the RFC determination was supported by substantial evidence, as summarized below.
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Residual functional capacity measures what a claimant can still do despite impairments, based on all relevant medical and other evidence, including evidence of mental limitations.

Hinson v. Kijakazi (CONSENT) · filed 2023-03-29(a)

An RFC determination is an assessment of what a claimant is still able to do despite the claimant’s impairments and is based on all relevant medical and other evidence. ... The medical evidence supports the ALJ’s RFC determination, which properly accounted for Plaintiff’s mental impairments.
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Section 404.1545(a) requires the ALJ to assess what a claimant can still do in light of physical and mental limitations.

(SS) Barbee v. Commissioner of Social Security · filed 2023-03-29(a)

In determining residual functional capacity, the ALJ must assess what the plaintiff can still do in light of both physical and mental limitations.
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Section 404.1545 defines residual functional capacity as the most a claimant can still do despite limitations, taking into account all medically determinable impairments.

Short v. Kijakazi · filed 2023-03-29

A claimant’s RFC is defined as the most a claimant can still do despite his or her limitations, taking into account all of a claimant’s medically determinable impairments.
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An RFC assessment must adequately explain why moderate limits in interacting with others do not also limit interaction with supervisors.

Carthron v. Saul · filed 2023-03-30(a)(1)

Viewing the record as a whole, however, the ALJ failed to provide adequate support for his conclusion that Plaintiff’s moderate limitations in interacting with others do not extend to supervisors. The decision is thus not supported by substantial evidence and must be remanded for further consideration of this issue.
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An RFC must account for moderate limitations in concentration, persistence, and pace, and the ALJ must explain the evidence supporting a two-hour concentration restriction.

Radosevich v. Kijakazi · filed 2023-03-31

The ALJ failed to explain how a restriction to “simple tasks requiring no more than two hours of continuous concentration” accounted for Radosevich’s ability to perform a simple task over an extended period of time.
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An RFC assessment must account for supported limitations in concentration, persistence, and pace when determining a claimant’s capacity for sustained work.

Capasso v. Saul · filed 2023-03-31(a)(1)

A claimant’s RFC is the ability to carry out physical or mental work activities on a sustained basis despite limitations from any impairments, 20 C.F.R. § 404.1545(a)(1), and is determined “based on all the claimant’s impairments and all the relevant evidence in the record.” Simila v. Astrue, 573 F.3d 503, 513 (7th Cir. 2009). ... The ALJ’s conclusion does not address Plaintiff’s limitations in concentration, persistence, and pace in any careful way, and does not consider the impacts of those limitations on her abilities to perform even simple work consistently.
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Section 404.1545 permits an RFC without mental restrictions when the ALJ evaluates the claimant’s mental impairments and explains why the evidence supports that assessment.

Garner v. Social Security Administration · filed 2023-03-31(c)

The Court finds that the ALJ’s overall evaluation of Plaintiff’s mental impairments is consistent with the conclusion that Plaintiff does not require mental restrictions in the RFC, and that the ALJ sufficiently described how the evidence supports his conclusion.
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An RFC need not include a restriction for a mild mental impairment when the ALJ adequately considers its functional impact and finds that no restriction is needed.

KRING-SCHREIFELS v. KIJAKAZI, ACTING COMMISSIONER OF SOCIAL SECURITY · filed 2023-04-26(a)(1)

Because the ALJ adequately addressed the mental health treatment evidence in the record in concluding that the functional impact of Plaintiff’s mental health impairment was so slight that it did not require inclusion in the RFC assessment or the hypothetical posed to the VE, tr. at 24, I find no error in the ALJ’s analysis.
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An RFC need not include mild mental limitations identified at steps two and three when the ALJ finds they have no consequential effect on the claimant’s ability to work.

Huchel v. Commissioner of Social Security Administration · filed 2023-04-27

After finding that Plaintiff had the above three mild limitations, he was “under no obligation” to include limitations in these areas in the RFC.
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An RFC describes what a claimant can still do despite physical and mental limitations; an ALJ need not include additional mental limitations when substantial evidence supports their omission.

Wiesman v. Commissioner of Social Security · filed 2023-06-22(a)(1)

A claimant’s RFC describes the most he can do in a work setting despite his physical and mental limitations. 20 C.F.R. § 404.1545(a)(1). ... Because these conclusions are supported by substantial evidence, the ALJ did not err by failing to include additional mental limitations in the RFC.
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Section 404.1545(a) requires the RFC to account for supported functional limitations, including those shown by medical evidence and the claimant’s testimony.

Parsons v. Commissioner Social Security Administration · filed 2023-06-26(a)

It did not mention Plaintiff’s flare-ups, or significant limitations contained in Plaintiff’s hearing testimony. Id. Thus, the RFC was defective. Valentine, 574 F.3d at 690.
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An RFC can account for mental functioning limitations by restricting a claimant to low-stress work with simple, routine tasks and limits on interaction and pace.

Pardini v. Kijakazi · filed 2023-06-29(a)(1)

In assessing Plaintiff’s RFC, the ALJ accounted for Plaintiff’s limitations in mental functioning, specifically by requiring work in a low-stress environment, which the ALJ defined as “simple, routine, repetitive tasks; no interactions with the general public; no fast pace production or work requirements, such [as] assembly line work; and no teamwork.” AR at 29.
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An RFC assessment must account for moderate social interaction limitations the ALJ found at step three.

(SS)Ramirez v. Commissioner of Social Security · filed 2023-07-07(a)(1)

Having made that finding at step three, the ALJ was required to incorporate the limitation in the RFC.
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An RFC may account for moderate limitations in concentration, persistence, and pace by restricting the claimant to simple routine tasks and instructions when the medical evidence supports that ability.

Zekanovic v. Commissioner of Social Security · filed 2023-07-10(a)

As such, the ALJ properly accounted for Plaintiff’s moderate limitations in concentration, persistence, and pace by incorporating in the RFC the limitation of simple routine tasks and instructions with reasoning level 1 or 2.
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Section 404.1545(a)(1) requires an RFC assessment based on all relevant evidence of a claimant’s physical and mental limitations, including the episodic effects of mental impairments.

Smith v. Commissioner of Social Security · filed 2023-07-31(a)(1)

To determine a claimant’s RFC, an ALJ makes an assessment based on all the relevant evidence of record as to what a claimant can do in a work setting despite any physical or mental limitations caused by the claimant’s impairments and related symptoms. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... Taking everything together, I cannot conclude that substantial evidence supports the ALJ’s RFC finding, as it is unclear whether the ALJ properly considered Plaintiff’s mental impairments, including the episodic nature of his bipolar disorder, or whether the ALJ therefore properly considered ARNP Keylani’s opinion regarding such impairments in the RFC assessment.
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Section 404.1545 requires an ALJ assessing residual functional capacity to consider mild limitations from a non-severe mental impairment and explain how they affect the assessment.

Key v. Commissioner of Social Security · filed 2023-08-01(a)(3)

Therefore, the ALJ was required to discuss how these mild limitations impact Plaintiff's RFC. The ALJ failed to explain the impact of Plaintiff's mild limitations in their RFC analysis.
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An RFC limited to simple tasks does not account for a moderate limitation in concentration; the ALJ must explain why the RFC omits a work-related limitation addressing it.

Robinson v. Commissioner of Social Security · filed 2023-08-01(a)(3)

Therefore, by restricting Plaintiff’s work to simple tasks, the ALJ did not account for Plaintiff’s moderate limitation on concentration. Furthermore, the ALJ did not provide any additional explanation for excluding additional work-related limitations into the RFC that would account for Plaintiff’s moderate limitation on concentration.
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An RFC may account for a moderate limitation in concentration, persistence, and pace through restrictions on task complexity, production pace, and quotas.

Winter v. Kijakazi · filed 2023-08-31(c)

These added restrictions clearly address Plaintiff’s moderate limitation in concentration, persistence, and maintaining pace.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations; restrictions to simple tasks, simple decisions, and occasional minor changes can account for mental impairments.

Phenes v. Commissioner of Social Security · filed 2023-09-07(a)(1)

Contrary to Plaintiff’s contention that the ALJ adopted “absolutely no mental limitations in her RFC,” limiting Plaintiff to simple tasks and decisions, with only occasional minor changes is a mental limitation that sufficiently accommodates Plaintiff’s impairments.
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Section 404.1545 requires an RFC assessment to include mental limitations supported by the evidence or explain their omission.

Tice v. Kijakazi · filed 2023-09-20(a)(3)

The Court finds that the ALJ erred by failing to include—or at least explain his failure to include—a limitation related to Plaintiff’s inability to do detailed and complex instructions in assessing her RFC.
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When a claimant has moderate limitations in concentration, persistence, and pace, the RFC assessment must explain how its restrictions address those limitations or why no restriction is needed.

Connelly v. Kijakazi · filed 2023-11-27(a)(1)

The Court agrees with Plaintiff that this lack of explanation warrants remand. A claimant’s RFC represents “the most [she] can still do despite [her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... On remand, the ALJ must either: (1) provide a narrative discussion that explains how the RFC addresses Plaintiff’s moderate CPP limitations or (2) explain why no RFC limitation is necessary to address these limitations.
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Section 404.1545(c) permits an ALJ to omit alleged mental limitations from an RFC assessment when the record lacks evidence of mental health issues and the claimant identifies no resulting limitation.

Davis v. Commissioner of Social Security · filed 2023-12-01(c)

With a dearth of objective medical evidence as to Plaintiff’s mental health during the Title II period and no specific claim by Plaintiff that he was limited by mental health issues, there was no error by the ALJ in not including any limitations based upon the alleged mental or psychological impact of the attack on Plaintiff in the RFC determination.
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Section 404.1545(a)(2) requires consideration of nonsevere medically determinable impairments when assessing residual functional capacity, but a mild mental limitation at Step 2 does not automatically require a corresponding RFC restriction.

Adams v. Commissioner of Social Security · filed 2023-12-12(a)(2)

In other words, a finding of mental limitation in analysis of the paragraph B criteria at Step 2 does not necessarily imply a corresponding limitation in a claimant’s RFC.
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Section 404.1545(a)(3) requires an RFC assessment to account for relevant evidence of a claimant’s limitations; an ALJ must explain an off-task limit that reduces distinct mental limitations to a single percentage.

Kaspar v. O'Malley · filed 2024-02-05(a)(3)

In determining a claimant’s RFC, the ALJ must base findings on “all of the relevant medical and other evidence,” including a claimant’s testimony regarding the limitations imposed by his impairments. ... The Court agrees that conflating multiple distinct limitations related to concentration, persistence, and pace to a singular limitation of “being off task 10% of a typical workday” is pure lay analysis. The ALJ has provided no rationale for the finding that Claimant would be off-task ten percent (10%) of a workday due to mental limitations.
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Section 404.1545(b) requires an RFC assessment to discuss the nature and extent of a claimant’s physical limitations, including sitting, standing, walking, and other physical functions.

Smith v. Social Security Administration · filed 2024-02-12(b)

This includes a discussion of the “nature and extent of” a claimant’s physical limitations including “sitting, standing, walking, lifting, carrying, pushing, pulling, or other physical functions (including manipulative or postural functions, such as reaching, handling, stooping, or crouching).” 20 C.F.R. §§ 404.1545(b), 416.945(b).
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Section 404.1545(a)(2) requires an ALJ to consider any mental impairment when determining a claimant’s residual functional capacity.

Duthorn v. Commissioner of Social Security Administration · filed 2024-03-04(a)(2)

In turn, the ALJ must consider any mental impairment when determining Plaintiff’s RFC.
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An RFC can account for a claimant’s response to stress through specific work-related mental limitations without a separate restriction to low-stress work.

Boykins v. Social Security Administration · filed 2024-03-06(a)(1)

Functional impairments must be set forth in work-related limitations that account for a claimant’s individualized reaction to stress. This is exactly what the ALJ did here, accounting for Plaintiff’s individualized ability to understand, remember, and carry out tasks, adapt to work changes, perform production, and tolerate interpersonal interaction. (R. 22.) Nothing more was required.
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Section 404.1545 requires an RFC to assess how mental impairments affect a claimant’s ability to meet work requirements.

Miller v. Commissioner of the Social Security Administration · filed 2024-03-12(a)(4)

It is not a list of mental impairments, but an assessment of how those impairments impact a claimant’s “ability to meet the physical, mental, sensory, and other requirements of work.” See 20 C.F.R. § 404.1545(a)(4); see also id. § 404.1545(c) (“When we assess your mental abilities, we first assess the nature and extent of your mental limitations and restrictions and then determine your residual functional capacity for work activity on a regular and continuing basis.”).
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Section 404.1545 requires an RFC assessment to reflect supported functional limitations; allegations of daily panic attacks need not produce further restrictions when the record does not support them.

Brown v. Commissioner of Social Security · filed 2024-03-20(a)(1)

The RFC assessment “is the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... Here, the ALJ adequately assessed Plaintiff’s subjective complaints of panic attacks, ultimately arriving at an RFC that is supported by substantial evidence.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite her limitations; an ALJ must explain how an RFC addresses moderate limitations in concentration, persistence, and pace, or why no RFC limitation is needed.

Heatherly v. Kijakazi · filed 2024-03-20(a)(1)

The Court agrees with Plaintiff that this lack of explanation constitutes error. A claimant’s RFC represents “the most [she] can still do despite [her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... On remand, the ALJ must either: (1) explain how the RFC addresses Plaintiff’s moderate CPP limitations or (2) explain why no RFC limitation is necessary to address these limitations.
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Section 404.1545(a)(4) requires consideration of a claimant’s ability to meet the mental requirements of work when assessing residual functional capacity, but speculation about earlier mental symptoms does not establish a limitation.

(SS) Lao v. Commissioner of Social Security · filed 2024-03-26(a)(4)

When assessing RFC, the ALJ must consider the claimant’s “ability to meet the physical, mental, sensory, and other requirements of work[.]” 20 C.F.R. §§ 404.1545(a)(4). ... However, in the absence of objective findings of mental impairment, and in light of plaintiff’s not mentioning depression at his 2016 disability hearing, plaintiff’s speculation about debilitating mental symptoms years earlier is not persuasive, and he has not shown error on this basis.
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Section 404.1545(a)(3) bases residual functional capacity on all relevant medical and other evidence; a sufficiently developed record can support that assessment without additional treating-source opinions.

Blakey v. Kijakazi · filed 2024-03-26(a)(3)

Even if this procedural history is not dispositive, here the ALJ had sufficient records from which he could determine Plaintiff’s RFC. See 20 C.F.R. § 404.1545(a)(3) (explaining that the RFC is determined “based on all of the relevant medical and other evidence”).
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Residual functional capacity is the most a claimant can do despite the claimant’s limitations.

Tucker v. O'Malley · filed 2024-03-26(a)(1)

A claimant’s “residual functional capacity is the most [he] can do despite [his] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1) (same); see McCoy v. Astrue, 648 F.3d 605, 614 (8th Cir. 2011) (“A claimant’s [residual functional capacity] represents the most he can do despite the combined effects of all of his credible limitations and must be based on all credible evidence.”); see also, e.g., Schmitt v. Kijakazi, 27 F.4th 1353, 1360 (8th Cir. 2022).
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Section 404.1545 requires an RFC assessment to account for a claimant’s physical and mental limitations.

Pleimann v. O'Malley · filed 2024-03-26

RFC is what a claimant can do despite his or her limitations and includes an assessment of physical abilities and mental impairments. 20 C.F.R. §§ 404.1545, 416.945. ... ALJ appears to have partially credited P.A. Scerba’s recommendation to limit Plaintiff’s capacity for overhead reaching but she ignored, without explanation, his recommendation to avoid heavy lifting.
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Residual functional capacity is the most a claimant can do in a work setting despite limitations caused by impairments.

CAMPBELL v. KIJAKAZI · filed 2024-03-26(a)(1)

An RFC assessment is the most a claimant can do in a work setting despite the limitations caused by his or her impairments. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).
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Section 404.1545(a)(1) requires consideration of all relevant evidence when assessing residual functional capacity; an impairment need not be included if it causes no significant work limitation.

(SS) Wagner v. Commissioner of Social Security · filed 2024-03-27(a)(1)

While the ALJ must consider all relevant evidence and case records, the ALJ is not necessarily required to include every impairment in the final RFC if the record indicates the non-severe impairment does not cause a significant limitation in the plaintiff’s ability to work.
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Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite limitations, assessed using all relevant evidence.

(SS) Goltz v. Commissioner of Social Security · filed 2024-03-27(a)(1)

The RFC is “the most [one] can still do despite [her] limitations” and represents an assessment “based on all the relevant evidence.”
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Residual functional capacity is assessed from the record as a whole and may be more restrictive than medical consultants recommend when substantial evidence supports it.

Donnellan v. Commissioner of Social Security · filed 2024-03-27(a)

The ALJ considered Donnellan’s condition as a whole, the RFC determination is supported by substantial evidence, and there is no reversible error in the ALJ’s arrival at a more restrictive RFC than that suggested by the state-agency consultants.
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Residual functional capacity is the most a claimant can still do despite limitations, and its assessment must be supported by the evidence.

Wilhite v. O'Malley · filed 2024-03-27(a)(1)

Prior to Step Four, the Commissioner assesses the Plaintiff’s residual functional capacity (“RFC”), 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4), which is “the most [a Plaintiff] can still do despite [his] limitations,” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... After a review of the record, the Court agrees with the Commissioner’s arguments and holds that substantial evidence supports the ALJ’s RFC assessment.
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Section 404.1545(a)(1) defines residual functional capacity as what a claimant can do despite limitations.

Emery v. O'Malley · filed 2024-03-27(a)(1)

The ALJ properly considered all available evidence and had substantial evidence to support his RFC determination. The RFC details what Plaintiff can do despite his limitations; it is determined by the ALJ and will be accepted as long as it is supported by substantial evidence.
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Section 404.1545 defines residual functional capacity as the most a claimant can still do despite limitations on a regular and continuing basis.

Worth v. Commissioner of Social Security · filed 2024-03-27(a)(1)

A claimant’s RFC is an assessment of “the most [he] can still do despite [his] limitations” “on a regular and continuing basis.” 20 C.F.R. §§ 404.1545(a)(1), (b)–(c); 416.945(a)(1), (b)–(c). ... But a review of the record together with the ALJ’s decision makes clear that the ALJ considered Plaintiff’s symptoms and impairments both singularly and in combination when crafting his RFC.
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An ALJ who considers mild mental limitations may omit separate restrictions from the residual functional capacity when those limitations are minimal.

Ramos-Troche v. Commissioner of Social Security · filed 2024-03-27(a)

The ALJ was not obliged to include minimal mental deficiencies in the RFC determination.
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Section 404.1545(a)(1) requires the ALJ to consider impairments and related symptoms that may limit what a claimant can do in a work setting when determining residual functional capacity.

Difiglia v. Commissioner of the Social Security Administration · filed 2024-03-28(a)(1)

To determine the claimant’s residual functional capacity (“RFC”), the ALJ must consider the claimant’s “impairment(s), and any related symptoms, [that] may cause physical and mental limitations that affect what [the claimant] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1).
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations, assessed based on all relevant evidence.

(SS) Moreno v. Commissioner of Social Security · filed 2024-03-29(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).
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Section 404.1545 allows an ALJ to assess mental residual functional capacity using clinical findings and consulting psychologists’ opinions, including an interaction limit more restrictive than those opinions.

GARCIA v. Commissioner of the Social Security Administration · filed 2024-03-31

Given the ALJ’s reliance on the mostly routine clinical findings explained above, the ALJ’s utilization of the consulting psychologists’ opinions, and the ALJ’s generation of a mental RFC arguably more restrictive than the psychologists’ opinions, there was no error in the ALJ’s generation of Plaintiff's mental RFC.
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Section 404.1545 does not require an ALJ to include limitations based on mild mental impairments in the residual functional capacity assessment at step four.

McNeal v. Kijakazi · filed 2024-04-02

The ALJ was not required to include limitations based on mild mental impairments in the hypothetical or the RFC assessment at step four of the sequential analysis.
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An RFC limiting a claimant to simple, routine work can account for moderate limitations in concentration, persistence, and pace when medical findings support that limitation.

Woodland v. Commissioner of Social Security · filed 2024-04-04

Under Stubbs-Danielson, Drs. Stephenson and Greenspan’s prior administrative medical findings constitute adequate support for the ALJ’s RFC.
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Section 404.1545(c) treats the ability to understand, remember, and carry out instructions as a mental work ability whose limitations may reduce the work a claimant can do.

Robinson v. Kijakazi · filed 2024-05-30(c)

The SSA classifies the ability to “understand[], remember[], and carry[] out instructions” as a mental ability which, if limited, “may reduce [the] ability to do past work and other work.” 20 C.F.R. §§ 404.1545(c), 416.945(c). ... Despite the function’s relevance to the outcome of this case, the ALJ failed to assess it, leaving the Court unable to determine whether a limitation to following short instructions was properly omitted from the RFC assessment.
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A residual functional capacity assessment may omit mental limitations when the record supports finding none during the period at issue.

Hornsby v. O'Malley · filed 2024-06-26(a)(1)

The ALJ did not include mental limitations in the RFC prior to April 13, 2017 because throughout that period, Plaintiff received no treatment for any psychiatric impairments, had normal mental status examinations, exhibited no mental health symptoms, and was not prescribed any psychotropic medications. (R. 1057, 1063). The Court finds no error in this assessment.
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Section 404.1545(a) defines residual functional capacity as the most a claimant can do despite their limitations.

CLOUSER v. KIJAKAZI · filed 2024-07-01(a)

The Social Security regulations explain that a claimant’s RFC is the “most” that they can do despite their limitations.
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An RFC restriction to unskilled work generally accommodates moderate limitations in social interaction.

Tiffany v. Commissioner of Social Security · filed 2024-06-28(c)

Such interaction limitations are generally accounted for adequately by restricting an individual to unskilled work – a limitation contained in the RFC formulated by the ALJ in this case.
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An ALJ’s residual functional capacity finding must have record support; a specific sitting and standing limitation cannot rest on the ALJ’s own surmise.

Hardmon v. Commissioner of Social Security · filed 2024-07-01

In sum, the ALJ erred in formulating a specific RFC limitation that finds no support in the record, and that error was not harmless. On remand, the ALJ must fashion an RFC that is based on evidence in the record and not on his own surmise.
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An RFC may account for moderate limitations in concentration, persistence, or pace through a restriction to simple instructions and routine tasks when the evidence supports those abilities.

Shumate v. Commissioner of Social Security · filed 2024-07-15(a)

Thus, the ALJ accounted for Plaintiff’s moderate limitations in concentrating persisting, or maintaining pace, in the RFC by limiting Plaintiff to understanding, remembering, and carryout simple instructions and performing simple routine tasks as consistent with unskilled work.
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Section 404.1545(a) treats residual functional capacity as the most a claimant can do, permitting an ALJ to adopt a broader task limitation when the evidence supports it.

Dunn v. O'Malley · filed 2024-07-17(a)

Because the doctors opined that Dunn could perform both kinds of tasks, the ALJ’s decision to adopt the broader limitation was reasonable. See 20 C.F.R. §§ 404.1545(a), 416.945(a) (noting an RFC represents the most a claimant can do, not the least).
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations; the assessment can encompass a range of ability when symptoms fluctuate.

Buxton v. O'Malley · filed 2024-07-23(a)(1)

Moreover, as the Commissioner notes correctly [Dkt. 18 at 17], the RFC would naturally be expected to encapsulate the range of ability by Plaintiff. 20 C.F.R. § 404.1545(a)(1) (“Your residual functional capacity is the most you can still do despite your limitations”).
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Section 404.1545(a)(1) defines residual functional capacity as the most work a claimant can still perform despite limitations.

Crist · filed 2024-07-30(a)(1)

A claimant’s RFC is an assessment of the most work the claimant can physically and mentally perform, not the least.
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Section 404.1545 governs the assessment of residual functional capacity; an ALJ need not include every limitation proposed by a reviewing physician.

Bailey v. Social Security Administration, Commissioner · filed 2024-07-31

However, Bailey’s argument ignores the opinion of one state agency physician who imposed limitations consistent with the RFC finding; applicable law does not require an ALJ to include every limitation a reviewing physician imposes; and the court does not construe the state agency consultant’s assessment as necessarily inconsistent with the RFC finding.
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Residual functional capacity measures the most a claimant can do despite impairments and is based on all relevant evidence.

Rodgers v. Social Security Administration · filed 2024-07-31(a)(1), (a)(3)

The RFC is an administrative finding, based on all relevant evidence, that an ALJ makes as to the most a claimant can do despite her impairments. See 20 C.F.R. §§ 404.1545(a)(1), (a)(3), 404.1546(c).
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Notes 3901–4050 of 6,798, oldest cases first.

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