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 still do despite their limitations.
Falconer v. O'Malley · filed 2024-08-01(a)(1)
If the claimant does not meet or equal a listing, the ALJ proceeds to step four and assesses the claimant’s residual functional capacity (“RFC”), defined as the most the claimant can still do despite their imitations (20 C.F.R. § 404.1545(a)(1)), and determines whether they are able to perform past relevant work, defined as “work that [the claimant has] done within the past 15 years, that was substantial gainful activity, and that lasted long enough for [the claimant] to learn to do it.” 20 C.F.R. § 404.1560(b)(1).Read the full opinion on CourtListener →
An RFC need not include mental limitations when the ALJ considers the claimant’s mental impairments and substantial evidence supports finding no resulting work limitations.
Blackmon v. Commissioner of Social Security · filed 2024-07-22(c)
Here, the ALJ did not err in failing to include any mental limitations in Blackmon’s RFC because it appropriately considered the record evidence regarding her non-severe mental impairments at step four of the sequential evaluation, and its decision is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(c) requires an RFC assessment to account for mental limitations; a restriction on hourly quotas and assembly-line work can account for moderate limitations in concentration, persistence, or pace when supported by the evidence.
Wilson v. Kijakazi · filed 2024-08-23(c)
Given this analysis, the ALJ’s decision provides the requisite “logical bridge” connecting the evidence of Plaintiff’s concentration issues to the RFC provision restricting Plaintiff from hourly quotas and assembly-line work.Read the full opinion on CourtListener →
An RFC may account for limitations in concentration, persistence, and pace through a restriction to simple, routine, repetitive tasks with concentration limited to two-hour segments.
Mcmahon v. Kijakazi · filed 2024-09-09
Not only did the ALJ limit plaintiff to simple, routine, repetitive tasks but he also expressly imposed a “concentration, persistence, and pace” restriction of two-hour segments.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to assess whether a mild mental limitation warrants a corresponding limitation in residual functional capacity.
Waller v. Commissioner, Social Security · filed 2024-08-23(a)(1)
The ALJ erred by failing to explore whether Plaintiff’s mild limitation in maintaining, concentration, persistence, or pace warrants a corresponding limitation in the RFC assessment.Read the full opinion on CourtListener →
An RFC assessment must account for the claimant’s limitations in understanding, remembering, or applying information.
Johnson v. O'Malley · filed 2024-09-23(a)(1)
In particular, the Court finds that the ALJ’s hypothetical questions to the vocational expert were materially consistent with the limitations included in the RFC, and that the RFC properly accounted for Plaintiff’s limitations in understanding, remembering, or applying information.Read the full opinion on CourtListener →
An RFC assessment must account for supported mental limitations, including limitations in social interaction and concentration.
Owens, II v. Commissioner of · filed 2024-09-26(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). ... The ALJ’s RFC findings on Plaintiff’s mental limitations are not supported by substantial evidence for two reasons. ... Accordingly, on key points in the mental RFC, the ALJ’s finding that the RFC is consistent with the evidence—including objective findings of Dr. Visser and Dr. Abraham—is not supported.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC assessment to account for a claimant’s work limitations; an ALJ must explain the rejection of proposed mental limitations using relevant evidence.
Pollard v. Commissioner of Social Security · filed 2024-11-14(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), 416.945(a). ... Here, remand is warranted because the Court is unable to discern the ALJ’s rationale for rejecting Dr. Butler’s opined work break and absenteeism limitations.Read the full opinion on CourtListener →
Section 404.1545(c) requires the ALJ to assess a claimant’s ability to perform mental activities in a work setting when determining mental residual functional capacity.
Venegas v. Commissioner of Social Security · filed 2024-12-13(c)
In determining the claimant’s mental RFC, in particular, the ALJ must assess the claimant’s abilities to carry out certain mental activities “in a work setting” such as “understanding, remembering, and carrying out instructions” and “responding appropriately to supervision, co-workers, and work pressures.” 20 C.F.R. § 404.1545(c).Read the full opinion on CourtListener →
An RFC includes cane use only when the cane is medically necessary.
Merritte v. O'Malley · filed 2024-12-16(a)(1)
A cane only needs to be incorporated into an RFC if it is a medical necessity. ... Viewing the record as whole, the ALJ did not commit reversible error by declining to include use of a cane in the RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an ALJ to consider all relevant medical and other evidence, including the claimant’s testimony about limitations, when assessing residual functional capacity.
Fidai v. O'Malley · filed 2024-12-17(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 her impairments.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the ALJ to consider all impairments, including non-severe impairments, when determining residual functional capacity.
Correa-Vargas v. Commissioner of Social Security · filed 2024-12-18(a)(2)
The Court finds that because the ALJ found at least one severe impairment at step two and continued in the evaluation process, the finding of severe or non-severe as to Plaintiff’s depression is, if erroneous, harmless as the ALJ considered all Plaintiff’s impairments when formulating 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, assessed from all relevant evidence.
(SS) Champion v. Commissioner of Social Security · filed 2024-12-18(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 →
Residual functional capacity describes what a claimant can still do despite impairments; the ALJ must consider all relevant evidence and clearly explain the finding.
WISNER v. O'MALLEY · filed 2024-12-19(a)
A claimant’s RFC, of course, is “that which an individual is still able to do despite the limitations caused by his or her impairment(s).” Fargnoli v. Massanari, 247 F.3d 34, 40 (3d Cir. 2001). See also 20 C.F.R. § 404.1545(a). Plaintiff is correct that, in formulating a claimant’s RFC, not only must an ALJ consider all relevant evidence, the RFC finding “must ‘be accompanied by a clear and satisfactory explication of the basis on which it rests.’” Fargnoli, 247 F.3d at 41 (quoting Cotter v. Harris, 642 F.2d 700, 704 (3d Cir. 1981)).Read the full opinion on CourtListener →
Section 404.1545(a) requires the ALJ to assess all the evidence when determining what a claimant can do despite limitations; an unsupported RFC provision requires remand when it may affect the disability determination.
Ranahan v. Commissioner of Social Security · filed 2024-12-20(a)
In determining a claimant’s RFC, the ALJ must assess all the evidence in the record to determine the most a claimant can do in a work setting despite their limitations. 20 C.F.R. §§ 404.1545(a), 416.945(a). ... Because the VE’s testimony indicated Plaintiff may not be able to complete the training period for the identified jobs without the unsupported provision in the RFC, this error may have affected the ultimate disability determination. Therefore, the error was not harmless, and remand is required.Read the full opinion on CourtListener →
An RFC assessment can account for fatigue through work limitations, and a claimant alleging additional concentration limits from medication must identify supporting record evidence.
Koepsel v. O'Malley · filed 2025-01-08
Plaintiff also asserts that the ALJ failed to consider the impact of Plaintiff’s medications, including causing drowsiness, but as already noted, the ALJ expressly stated that the RFC limitations were due, in part, to Plaintiff’s fatigue. And, in any event, Plaintiff fails to point to any record evidence that the ALJ ignored indicating that her medications exacerbated her problems concentrating.Read the full opinion on CourtListener →
Section 404.1545(a)(1) measures residual functional capacity by the most work a claimant can perform despite her limitations; moderate mental limitations do not require greater restrictions without supporting evidence.
Mares v. O'Malley · filed 2025-01-13(a)(1)
A claimant’s RFC is the maximum work that she can perform despite any limitations. ... Viewing the record as a whole, the ALJ did not err in finding that plaintiff is capable of performing a range of work notwithstanding her moderate mental limitations, and that decision is supported by substantial evidence.Read the full opinion on CourtListener →
An ALJ may determine residual functional capacity from the record without adopting the only medical opinion.
Hancock v. Colvin · filed 2025-01-14(a)(1)
As an initial matter, an ALJ is not required to adopt or give heightened weight to a medical opinion simply because it is the only one of record. ... In light of this standard, the Court finds that the ALJ’s assessment of the evidence of record and the ultimate RFC determination fall within the “zone of choice.”Read the full opinion on CourtListener →
Section 404.1545(c) requires an assessment of mental abilities when determining residual functional capacity; the ALJ’s review of psychological opinions at step four can provide the required assessment.
Watson v. Commissioner Of Social Security · filed 2025-01-23(c)
In contrast with Schink, the ALJ here not only reviewed the paragraph B criteria at step two, but also reviewed the persuasiveness of the state psychological consultants’ opinions at step four and in relation to the RFC.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to reflect work-related limitations supported by the record; mental impairments need no RFC restriction when they cause no functional limitation.
Andriola v. O'Malley · filed 2025-01-23(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. ... Viewing the record as a whole, the ALJ did not commit reversible error in determining that plaintiff has no functional limitations stemming from his mental impairments.Read the full opinion on CourtListener →
Section 404.1545(a) permits an ALJ to include a simple-instructions limitation in the RFC when medical consultants find that the claimant can follow simple instructions and sustain simple one-to-two-step tasks.
(SS) Chaffin Wall v. Commissioner of Social Security · filed 2025-02-06(a)
The ALJ then adopted the broader limitation into the RFC, which the Court finds was reasonable. See 20 C.F.R. §§ 404.1545(a), 416.945(a).Read the full opinion on CourtListener →
Section 404.1545(a)(1) treats residual functional capacity as an assessment of a claimant’s ability to work despite impairments; the assessment must address the effect of an identified moderate limitation in concentration, persistence, or pace.
Hames v. Social Security Administration, Commissioner · filed 2025-03-03(a)(1)
This technique, however, is separate from the ALJ’s evaluation of the claimant’s RFC, the latter of which is an assessment of the claimant’s ability to do work despite his impairments. See Winschel, 631 F.3d at 1180; Lewis, 125 F.3d at 1440; 20 C.F.R. § 404.1545(a)(1); 20 C.F.R. § 416.945(a)(1). ... Thus, the ALJ did not include an assessment or explanation in the RFC determination of the impact of Hames’s moderate limitation in concentrating, persisting, or maintaining pace.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess residual functional capacity without relying on a particular medical opinion.
Poe v. Dudek · filed 2025-03-03(a)(3)
The ALJ was not required to rely on a particular medical opinion in making the RFC assessment.Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as the most a claimant can still do despite limitations.
Roman v. Commissioner of Social Security · filed 2025-03-03(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), 416.945(a)(1).Read the full opinion on CourtListener →
An RFC must account for supported limitations in concentration, persistence, and pace; a restriction to simple, routine, repetitive tasks may be insufficient.
Alvarez v. Commissioner of Social Security · filed 2025-03-04(a)
As in Crump, the Court finds that the ALJ’s RFC did not account for Plaintiff’s difficulties with concentration, persistence, or pace. Limiting Plaintiff to “simple, routine, and repetitive tasks, requiring only simple work related decisions, with few changes in the routine work setting” was insufficient to address his workplace limitations.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC to account for supported moderate limitations in concentration, persistence, and pace; an ability to perform simple tasks does not substitute for those limitations.
Burnette v. Commissioner of Social Security · filed 2025-03-05
But none of these scenarios apply here given that nothing in the RFC can be read as a substitute for moderate concentration, persistence, and pace.Read the full opinion on CourtListener →
Section 404.1545(a)(1) describes residual functional capacity as the work-related abilities a claimant retains despite limitations.
Munger v. Commissioner of Social Security Administration · filed 2025-03-07(a)(1)
The RFC determination sets out an individual’s work-related abilities despite his or her limitations. See 20 C.F.R. § 404.1545(a)(1). ... Substantial evidence supports the RFC findings regarding Munger’s ability to handle, finger, and feel.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite physical or mental limitations; the assessment may be upheld when substantial evidence supports it.
Scarbrough v. Dudek · filed 2025-03-07(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). ... The Court holds that substantial evidence supports the ALJ’s decision, for several reasons.Read the full opinion on CourtListener →
An ALJ may omit mental limitations from a residual functional capacity assessment when the decision considers the claimant’s mental impairments and adequately explains the omission.
Brueggemann v. Dudek · filed 2025-03-07(a)(2)
The Court finds that these four clear references to Brueggemann’s mental abilities demonstrate that the ALJ considered and adequately explained why she concluded that Brueggemann’s RFC does not include any mental impairments.Read the full opinion on CourtListener →
Residual functional capacity measures the most a claimant can still do despite limitations, rather than the least.
Hobson v. Commissioner of Social Security · filed 2025-03-07(a)(1)
In other words, the RFC is not the least an individual can do despite his or her limitations or restrictions, but the most. See Young v. Barnhart, 362 F.3d 995, 1000-01 (7th Cir. 2004); 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite his or her limitations.
Greenwood v. Dudek · filed 2025-03-11(a)(1)
A claimant’s RFC is the most he or she can do despite his or her limitations.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.
Hearod v. Dudek · filed 2025-03-11(a)
Likewise, the ALJ properly evaluated Plaintiff’s impairments in the context of determining her RFC at step four. A claimant’s RFC is defined as “what [the claimant] can still do” despite her “physical or mental limitations.” 20 C.F.R. § 404.1545(a).Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an ALJ to assess what a claimant can do in a work setting despite physical or mental limitations, based on all relevant evidence.
Lawton v. Commissioner of Social Security · filed 2025-03-12(a)(1)
To determine a claimant’s RFC, an ALJ assesses, based on all the relevant evidence of record, 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). ... In sum, the ALJ conducted a detailed assessment and properly considered Plaintiff’s overall condition in electing not to include further mental limitations in the RFC.Read the full opinion on CourtListener →
An RFC must account for supported work limitations or explain why they are rejected; limits to simple, routine tasks and reduced social contact do not necessarily account for difficulty completing a workday or handling workplace stress and changes.
(SS) Phounsavath v. Commissioner of Social Security · filed 2025-03-06(a)
Based on the foregoing, the Court finds the RFC limiting Plaintiff to simple, routine tasks with only occasional public contact, occasional tasks that require teamwork, no quota-driven work, and working “mainly with objects and not people” (AR 7), does not account for Dr. Bonilla’s findings of moderate limitations in Plaintiff’s ability to complete a normal workday/work week and deal with stress and changes encountered in the workplace. The Appeals Council’s failure to provide reasons, supported by substantial evidence, to reject those limitations, particularly as to her ability to complete a workday/work week and deal with stress and changes, or to properly incorporate those limitations into the assessed RFC, constitutes error.Read the full opinion on CourtListener →
An ALJ may incorporate medical opinions limiting a claimant to simple instructions into an RFC restriction to simple repetitive tasks when that restriction adequately reflects the opinions.
Bell v. O'Malley · filed 2025-03-14(a)
The ALJ found persuasive that Drs. Foster-Valdez and Ying’s opinions were consistent with Dr. Sharokhi’s opinion and the other evidence in the record, in assessing Plaintiff’s RFC to include a limitation to “simple repetitive tasks.” (AR 21, 25.) The Court finds no error by the ALJ in adequately incorporating Drs. Foster-Valdez and Ying’s opinions into Plaintiff’s RFC.Read the full opinion on CourtListener →
Section 404.1545 permits an RFC without mental health restrictions when the ALJ considers the relevant evidence and explains why those restrictions are unsupported.
Walz v. Dudek · filed 2025-03-14(a)(1)
As such, the ALJ adequately considered Plaintiff’s mental health and explained why the RFC did not include any restrictions related to her mental health.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires the ALJ to explain why mental limitations found in the record do or do not result in functional limitations in the RFC.
Thoms v. O'Malley · filed 2025-03-17(a)(1)
As such, and because the ALJ failed to explain why the mild mental limitations he found did not translate to functional limitations in his RFC, this matter must be remanded so the ALJ may do so and consider any new RFC assessed against Dianne’s past work.Read the full opinion on CourtListener →
An RFC must account for a claimant’s supported limitations based on all relevant evidence; limits on task complexity, pace, and interaction can address moderate concentration and social limitations.
Trussel v. O'Malley · filed 2025-03-17(a)(1)
When crafting the RFC and hypothetical, the ALJ accounted for the “totality of” Lena’s restrictions, including those relating to CPP and social interaction deficits, by limiting Lena to “simple, routine tasks involving simple work-related decisions that do not require a fast production rate pace” and “occasional interaction with coworkers, supervisors, and the public.” (Id. at 16-17.)Read the full opinion on CourtListener →
Residual functional capacity assesses what a claimant can still do despite physical and mental limitations.
(SS) (PS) Cantrell v. Commissioner of Social Security · filed 2025-03-19(a)
In determining residual functional capacity, the ALJ must assess what the plaintiff can still do in light of both physical and mental limitations.Read the full opinion on CourtListener →
An RFC assessment need not include limitations the ALJ properly rejects as unsupported by the evidence.
Cordova v. Commissioner of Social Security · filed 2025-03-20(a)
Importantly, the ALJ need not include limitations in the RFC that the ALJ properly rejected as unsupported by the evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires consideration of nonsevere impairments, but mild mental limitations need not be included in the RFC when they cause no more than minimal limitations in basic work activities.
Hernandez v. Commissioner of the Social Security Administration · filed 2025-03-20(a)(2)
Therefore, the ALJ did not need to include the mild mental limitations in the RFC.Read the full opinion on CourtListener →
An RFC states what a claimant can still do despite limitations; a vague reference to a low stress working environment need not be included.
Harvey v. Dudek · filed 2025-03-24(a)(1)
And because “RFC is defined as the most a claimant can still do despite his or her physical or mental limitations,” Martise, 641 F.3d at 923 (emphases added) (citation omitted), nothing mandated that the ALJ include Harvey’s vague reference to a “low stress working environment,” Tr. 26, in the RFC, see, e.g., 20 C.F.R. § 404.1545(a)(1) (“Your [RFC] is the most you can still do despite your limitations.”).Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ to assess the evidence when determining residual functional capacity; supported restrictions on tasks and social contact can account for moderate mental limitations.
(SS) Layfield v. Commissioner of Social Security · filed 2025-03-24(a)
When creating the residual functional capacity, the ALJ did account for the moderate limitations where the ALJ considered Dr. Garland’s limitations, included a more restrictive limitation of no interaction with the public, and included the limitation of occasional interaction with co-workers and supervisors.Read the full opinion on CourtListener →
An RFC assessment translates paragraph B mental limitations into functional limits supported by medical evidence.
Jordan v. O'Malley · filed 2025-03-27
Therefore, the relevant inquiry into an ALJ's translation of the moderate limitations found in paragraph B to a functional limitation in the RFC is whether the RFC limitations are supported by medical evidence.Read the full opinion on CourtListener →
An RFC under § 404.1545 can account for moderate mental limitations through specific work-related restrictions.
Reyes v. Commissioner of Social Security · filed 2025-03-27(a)(1)
Plaintiff challenges the RFC as not including all of Plaintiff’s mental limitations, but the ALJ’s articulated mental-related functions in the RFC adequately account for the moderate limitations in each of the four broad functional areas.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple, repetitive tasks may account for moderate limitations in concentration, persistence, or pace when supported by the record.
(SS) Celillo v. Commissioner of Social Security · filed 2025-04-15(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). ... Based on this record, the ALJ’s conclusion that plaintiff could perform simple, repetitive tasks (despite moderate limitations in concentration, persistence, or pace) is consistent with Stubbs-Danielson and supported by substantial evidence.Read the full opinion on CourtListener →
An RFC assesses what a claimant can do despite limitations; omitting mental restrictions is harmless when the claimant identifies no evidence-based work restrictions to add.
Hagewood v. Commissioner of Social Security · filed 2025-06-20(a)(1)
The Plaintiff points to no testimony or medical records about work restrictions related to “understanding, remembering, or applying information,” “interacting with others,” “concentration, persistence, and pace,” or “adapting or managing oneself.” ... Thus, the Plaintiff has failed to show that the ALJ committed a harmful error in the RFC assessment.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple, routine tasks can account for moderate impairments in concentration, persistence, and pace when it is consistent with the medical opinion.
Raab v. O'Malley · filed 2025-08-07(a)(1)
In accordance with Ninth Circuit authority, the Court finds the ALJ’s RFC limiting Plaintiff to simple, routine tasks is consistent with, and sufficiently accounts for, Dr. Shertock’s opined moderate impairments in concentration, persistence, and pace.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an RFC assessment to account for medically determinable mental limitations, including mild limitations, or explain why they do not affect the claimant’s ability to work.
Vandergraff v. Commissioner of Social Security · filed 2025-08-07(a)(2)
Without incorporating the other mental functioning limitations, the RFC assessment is incomplete. Perhaps the ALJ believed that the mild nature of the limitations had no bearing on Ms. Vandergraff’s ability to work, but there’s no way for the Court to know.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an ALJ who finds an opinion limiting a claimant to one-to-two step tasks persuasive to include that limit in the RFC or explain its omission.
Coleman v. Bisignano · filed 2025-08-19(a)(1)
Christine correctly argues that the ALJ needed to either include a one-to-two step task limitation in the RFC or explain why it was not warranted because she deemed the state agency reviewing psychologists’ opinions “persuasive.”Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to account for credibly established mental limitations.
JONES v. O'MALLEY · filed 2025-09-05(a)(2)
The ALJ sufficiently accounted for the PRT’s findings when explaining her determination of Aisha J.’s RFC by considering all limitations credibly established by the record.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an RFC assessment to account for supported limitations in concentration, persistence, and pace.
Spillers v. Commissioner of Social Security · filed 2025-09-22(a)(2)
In summary, the Court finds that the ALJ failed to incorporate moderate limitations in concentration, persistence, and pace into the RFC. As a result, remand is required.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple, routine, repetitive tasks can account for moderate limitations in concentration, persistence, and pace when the record supports that assessment.
McEntire v. O'Malley · filed 2025-09-25
The ALJ made the RFC finding after expressly stating that the “paragraph B” ratings were accounted for in the RFC, and the limitations in the RFC are the type that adequately account for a moderate rating in the “paragraph B” area.Read the full opinion on CourtListener →
In assessing residual functional capacity, an ALJ may satisfy the obligation to address mental limitations by discussing them to some degree at step four.
Padilla v. Commissioner, Social Security Administration · filed 2025-09-25
Moreover, an ALJ’s obligation at step four may be satisfied when the ALJ discusses the plaintiff’s mental limitations to some degree at that step.Read the full opinion on CourtListener →
Section 404.1545(a) requires the RFC assessment to account for supported limitations or explain why they were rejected.
Cortez v. Commissioner of Social Security · filed 2025-09-25(a)
Based on the foregoing, the Court finds the RFC limiting Plaintiff to routine, simple work tasks involving one to three step work tasks, not requiring a fast assembly quota pace (i.e., fast assembly line environment where one’s work impacts work down the line), and allowing that Plaintiff would be off task up to 3% of the workday, does not account for Dr. Cross’s findings of moderate limitations in Plaintiff’s ability to ability to understand, remember, carry out simple one or two-step job instructions over an 8-hour day 40-hour work week without emotionally decompensating, and maintain regular attendance in the workplace and perform activities on a consistent basis. The ALJ’s failure to either provide reasons, supported by substantial evidence, to reject those limitations or to properly incorporate those limitations into the assessed RFC, constitutes error.Read the full opinion on CourtListener →
Section 404.1545 allows an RFC assessment to include a limitation for reported symptoms that is more restrictive than the medical opinions without generally creating reversible error.
Manka v. Commissioner of Social Security · filed 2025-09-26
An ALJ’s decision to extend the benefit of the doubt to a claimant and to include additional limitations in an RFC to account for self-reported symptoms is not generally a reversible error.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of mental impairments in assessing residual functional capacity, but mild impairments need not produce work restrictions when the record supports finding no work-related limitations.
ANGROS v. DUDEK · filed 2025-09-23(a)(2)
The ALJ sufficiently explained the limitations she considered in forming plaintiff’s RFC, taking into account plaintiff’s medical record as a whole and considered the medical source opinions about plaintiff’s mental health impairments. ... The record supported the ALJ’s determination that plaintiff’s mild mental health impairments had no work-related limitations.Read the full opinion on CourtListener →
A severe mental impairment found at step two does not automatically require a corresponding restriction in the residual functional capacity assessment.
Adkins · filed 2025-10-10(c)
As the Court previously explained, to the extent Claimant suggests that a finding of a severe mental impairment at step two necessarily requires limitations on a claimant’s ability to perform basic work activities, that argument has no merit.Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ to account for a supported sitting limitation in the residual functional capacity or explain why it was excluded.
Burton v. Commissioner of Social Security · filed 2025-10-17(a)
Accordingly, the Court finds that the ALJ’s failure to either include a sitting limitation in the residual functional capacity and incorporate it into the hypothetical posed to the vocational expert, or failure to reject the 6-hour sitting limitation and explain why, was not harmless error.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC assessment to consider all relevant evidence; it need not match a medical opinion if substantial evidence supports it.
Velez · filed 2025-10-20(a)(1)
The RFC is “based on all the relevant evidence” in the record. 20 C.F.R. § 404.1545(a)(1) (emphasis added); accord Laborin v. Berryhill, 867 F.3d 1151, 1153 (9th Cir. 2017). ... The mere fact that the RFC did not mirror the PAMFs finding only non-severe impairments does not require a finding on appeal that the ALJ erred.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; the assessment must account for material evidence of those limitations.
SIERRA · filed 2025-10-22(a)(1)
The Court is not persuaded that substantial evidence supports the ALJ’s consideration of Plaintiff’s IBS symptoms and their effect on the RFC. A claimant’s RFC is the most that the claimant can do despite her limitations. 20 C.F.R. § 404.1545(a)(1). ... Where the ALJ selectively cited to treatment notes that supported his assessment but ignored contrary portions without explanation, the Court cannot follow the ALJ’s reasoning or otherwise conclude that substantial evidence supports the ALJ’s consideration of Plaintiff’s IBS and the RFC determination.Read the full opinion on CourtListener →
Section 404.1545 does not require an ALJ to include mental restrictions in the RFC when substantial evidence supports only mild limitations in mental functioning.
Zeigler · filed 2025-10-28
But when substantial evidence in the record supports only mild limitations in mental functioning, an ALJ is not required to include mental limitations or ... restrictions in the RFC.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to explain how the evidence supports the claimant’s residual functional capacity.
Combs · filed 2025-11-04
Because the ALJ’s discussion does not describe how the evidence supports the residual functional capacity finding, it “contains too little logical explanation for . . . meaningful appellate review.”Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do in a work setting despite functional limitations.
Ayesha M. Lee v. Dudek · filed 2025-11-04(a)(1)
The residual functional capacity is a finding as to the most a claimant can still do in a work setting despite her functional limitations, 20 C.F.R. § 404.1545(a)(1).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, assessed using all relevant evidence.
Palmer v. Bisignano · filed 2025-11-10(a)(1)
The RFC is “the most [one] can still do despite [his] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
An RFC measures what a claimant can still do despite her limitations, based on all relevant evidence in the administrative record.
Klein · filed 2025-11-17(a)(1)
An RFC measures the tasks a person can perform given her limitations based on “all the relevant evidence” in the administrative record. ... Because the court cannot trace the ALJ’s path of reasoning from the evidence to his conclusion, this case must be remanded.Read the full opinion on CourtListener →
An RFC assessment must account for supported moderate limitations in concentration, persistence, or pace, including their effect on the ability to sustain work throughout a workday.
Ballard · filed 2025-10-22(a)(1)
Because of this “disconnect[,]” id., between Ballard’s moderate limitations in concentration, persistence, or pace found by the ALJ and the assigned RFC for “simple instructions and tasks” (AR 31), the ALJ’s decision will be reversed and the case remanded to reassess the mental RFC and the hypotheticals posed to the VE at step five.Read the full opinion on CourtListener →
An RFC must account for all medically determinable impairments; a restriction to simple tasks can adequately account for moderate persistence limitations.
Walsh · filed 2025-10-30(a)(2)
It is true that the RFC must account for all a claimant’s Medically Determinable Impairments, both severe and non-severe. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2). ... This Court finds that the ALJ reasonably assessed Plaintiff’s persistence limitations and accounted for them in the RFC. At the heart of Plaintiff’s claim that the ALJ committed harmful error is the question of whether a restriction to simple tasks sufficiently addresses her persistence limitations. The Court holds that it does.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple instructions and unskilled work can account for moderate limitations in concentration, persistence, and pace when the record supports that capacity.
Crawford · filed 2025-12-23
Based on the entirety of Crawford’s administrative record, the ALJ’s limiting of Crawford to simple instructions and unskilled work sufficiently accounted for his moderate limitations in concentration, persistence, and pace.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 in the case record.
Crowe · filed 2025-12-29(a)(1)
The claimant must provide evidence establishing his or her residual functional capacity (RFC), which “is the most [the claimant] can still do despite [his or her] limitations,” and is assessed using “all the relevant evidence in [the] case record.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider all medically determinable impairments, including non-severe impairments, and relevant testimony from medical providers and the claimant.
Kuester · filed 2025-12-29
The RFC must contemplate all medically determinable impairments, including those which the ALJ found non-severe, and evaluate all the relevant testimony, including the opinions of medical providers and the subjective symptom testimony set forth by the claimant.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider the evidence of a claimant’s limitations when determining residual functional capacity.
Marvin P.R. v. Commissioner of Social Security · filed 2025-12-29(a)
In determining what a claimant’s RFC is, “the ALJ must consider all evidence before [her].” Burnett, 220 F.3d at 121 (emphasis added). ... Here, the record is replete with evidence that Marvin suffered from persistent dizziness but the ALJ’s findings, while otherwise thorough, did not address either the credibility of those symptoms or their impact on Marvin’s RFC. Because the ALJ did not adequately address Marvin’s dizziness, her conclusion regarding Marvin’s ability to perform sedentary work lacks a complete foundation.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite limitations that affect work activities.
GRECCO · filed 2025-12-29(a)(1)
Under C.F.R. § 404.1545, a claimant's RFC is “the most [he or she] can do” despite limitations “that affect what [he or she] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
Residual functional capacity accounts for limitations supported by the record when assessing a claimant’s ability to work despite impairments.
Pumroy · filed 2025-12-30(a)(1)
The ALJ properly determined the RFC. The RFC properly accounts for Plaintiff's limitations for which the record provides support.Read the full opinion on CourtListener →
An RFC assessment need not match a specific medical opinion if substantial evidence supports it.
Serie H. v. Bisignano · filed 2025-12-30(a)(1)
The RFC determination is an administrative finding reserved to the Commissioner, and it need not precisely mirror the language of a medical opinion so long as it is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to assess the most a claimant can still do despite limitations, considering all relevant medical and other evidence.
Youngblood · filed 2025-12-30(a)
A claimant’s RFC is the most that he can still do despite his limitations, and it is the ALJ’s responsibility to make the RFC assessment by considering all relevant medical and other evidence in the record.Read the full opinion on CourtListener →
Residual functional capacity includes limitations on what a claimant can still do; a statement that a companion animal would be beneficial does not, by itself, establish a limitation to include.
Wilhelm · filed 2026-01-07(a)(1)
Such statements do not suggest Plaintiff would be unable to work without a companion animal, so they do not suggest Plaintiff has further limitations which would need to be included in the Residual Functional Capacity. See 20 C.F.R. § 404.1545(a)(1) (“Your residual functional capacity is the most you can still do despite your limitations.”).Read the full opinion on CourtListener →
An ALJ need not include every limitation a claimant identifies in the residual functional capacity when the ALJ finds the claimant’s symptom testimony not credible.
Neary · filed 2026-01-13(a)(1)
Because the ALJ found Plaintiff to be not credible regarding her symptom testimony, the ALJ was not required to include all the limitations identified by Plaintiff in the RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(4) concerns the requirements of work; the ability to handle one’s finances alone has no bearing on residual functional capacity.
Keener · filed 2026-01-14(a)(4)
Dr. Wise did note her agreement with Plaintiff’s belief that she can handle her own finances but, as such a capability is not related to “the physical, mental, sensory and other requirements of work,” this has no bearing on the RFC determination and does not alone warrant categorizing Dr. Wise’s report as a medical opinion.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite established impairments.
OKUNAYA · filed 2026-01-15(a)(1)
A claimant’s RFC is what he can still do despite his established impairments. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ’s residual functional capacity assessment to account for limitations supported by the record.
Howard · filed 2026-01-16(a)(1)
The ALJ erred in determining Plaintiff’s RFC because it failed to include limitations that were supported by the record.Read the full opinion on CourtListener →
An RFC assessment may account for mild mental limitations through an allowance for time off task when the ALJ considers the claimant’s symptoms and supporting evidence.
MARSHACK · filed 2025-12-30(a)(1)
The Court agrees with Defendant. Specifically, in making this determination, the ALJ stated that it “considered all symptoms and the extent to which these symptoms can reasonably be accepted as consistent with the objective medical evidence and other evidence.” (AR at 861.) This undoubtedly includes the detailed discussion and analysis of Plaintiff’s mental impairments.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires consideration of mild mental limitations when assessing residual functional capacity.
EARL · filed 2026-01-23(a)(2)
The Court will reject the Commissioner’s initial point that the ALJ was not required to address this limitation because it was only found to be mild.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to assess a claimant’s mental limitations and restrictions when determining the ability to work on a regular and continuing basis.
Dixon · filed 2026-02-04(c)
The regulations require an ALJ to assess “the nature and extent of [the plaintiff’s] mental limitations and restrictions” to determine his ability to “work on a regular and continuing basis.” 20 C.F.R. § 404.1545(c).Read the full opinion on CourtListener →
A finding of mild mental limitations does not require the ALJ to include mental functioning restrictions in the residual functional capacity assessment.
Birner · filed 2026-01-28
At the outset, the Court notes that a finding of mild mental limitations does not require the ALJ to include mental functioning restrictions in the RFC.Read the full opinion on CourtListener →
An RFC assessment must address moderate mental limitations identified in medical opinions when the adopted narrative does not account for them.
Hardin · filed 2026-02-09(a)(1)
Remand is required for the ALJ to address the moderate checkbox limitations regarding time off task, absences, distraction, and behavioral extremes.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider the limiting effects of physical and mental impairments and to explain how the resulting restrictions account for those limitations.
Harlow · filed 2026-02-17(a)(1)–(3)
When assessing an RFC, an ALJ must consider the limiting impacts of a claimant’s physical and mental impairments. 20 C.F.R. §§ 404.1545(a)(1)–(3). ... Further, the ALJ did not explain how the restrictions relate to Joshua’s CPP limitations, rather than his limitations in the other functional areas.Read the full opinion on CourtListener →
Section 404.1545 does not require a moderate paragraph B mental limitation to become a corresponding work-related restriction in the RFC.
Jefferson · filed 2026-02-27(a)(1)
A moderate limitation in the paragraph B criteria does not necessarily translate to a work-related functional limitation in the RFC.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple, repetitive tasks and restricted social interaction can adequately account for moderate limitations in concentration, persistence, and pace.
Formaro · filed 2026-02-09(a)(1)
Under Winschel and its progeny, such limitations adequately accounted for the moderate limitations in concentration, persistence, and pace.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to consider medical evidence and a claimant’s symptoms when assessing residual functional capacity, including limitations related to work stress.
Hodge · filed 2026-03-03
In reaching an RFC determination, an ALJ must consider objective medical facts, diagnoses, medical opinions based on these facts, and the claimant’s subjective symptoms, including pain and other limitations. ... In sum, the ALJ’s assessment of plaintiff's ability to handle stress and accounting for those limitations in her RFC is proper and supported by substantial evidence.Read the full opinion on CourtListener →
An RFC assessment need not separately discuss every mild mental limitation if the analysis adequately considers those limitations.
Rodman · filed 2026-03-17(a)(1)
It is true that the ALJ did not incorporate an explicit, separate discussion for each of the remaining three Paragraph B categories. However, the failure to do so does not automatically warrant remand if the RFC analysis adequately considers her limitations. Mascio, 780 F.3d at 637. In the Court’s view, it does.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider all medically determinable impairments, including nonsevere mental limitations that may affect workplace interactions.
Albert H. v. Bisignano · filed 2026-03-18(a)(2), (c)
When determining the RFC, the ALJ must consider all medically determinable impairments, physical and mental, even those that are not considered “severe.” Id. § 404.1545(a)(2), (b), (c). Mental limitations 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.” Id. § 404.1545(c).Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to account for mild mental limitations in the residual functional capacity assessment by incorporating the analysis of those limitations from an earlier step.
Irizarry-Irizarry · filed 2026-03-19(a)(1)
The ALJ's evaluation of the Paragraph B criteria resulted in a finding that the mental impairment was not severe, and his incorporation of that analysis to the formulation of the RFC was sufficient.Read the full opinion on CourtListener →
Residual functional capacity must account for supported limitations in responding to supervision.
Wear v. Commissioner Social Security Administration · filed 2016-01-28(c)
In sum, the ALJ gave “significant weight” to Dr. Moore’s opinion, yet .the RFC failed to incorporate Dr. Moore’s opinion as to Plaintiffs limitation in responding to authority. ... Therefore, when Plaintiffs limitation in responding to supervisors is properly included in the RFC, the ALJ and the VE concur that Plaintiff is disabled.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.
Solis v. Berryhill · filed 2019-08-06(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).Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations; the assessment considers opinion evidence alongside the other evidence in the record.
GREISINGER v. BERRYHILL · filed 2019-08-14(a)
RFC refers to the most a claimant can still do despite his/her limitations. 20 C.F.R. §§ 404.1545(a), 416.945(a). ... After a review of the record, I find that the ALJ properly evaluated the opinion evidence in relation to all of the other evidence (including, inter alia, activities of daily living) to determine the RFC.Read the full opinion on CourtListener →
Residual functional capacity measures the most a claimant can do despite impairments.
Eppinger v. Social Security Administration, Commissioner of · filed 2019-08-14(a)(1)
A claimant’s RFC is the most the claimant can do, not the least, despite his or her impairments. 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to use all relevant evidence to assess a claimant’s ability to sustain work activities despite impairments.
Foster v. SSA · filed 2019-08-15
Before moving to the fourth step, the ALJ must use all the relevant evidence in the record to determine the claimant’s residual functional capacity (RFC), which is an assessment of one’s ability to perform certain physical and mental work activities on a sustained basis despite any impairment experienced by the individual. See 20 C.F.R. § 404.1520(e); 20 C.F.R. § 404.1545. ... Foster’s already highly restrictive RFC was properly assessed.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as what a person can still do despite limitations from physical and mental impairments.
Mohamed v. Saul · filed 2019-08-20(a)(1)
The residual functional capacity (“RFC”) is what a person is still capable of doing despite limitations resulting from her physical and mental impairments.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite the physical and mental limitations caused by impairments.
Foutty v. Commissioner of Social Security · filed 2019-08-20(a)
A plaintiff’s RFC “is defined as the most a [plaintiff] can still do despite the physical and mental limitations resulting from her impairments.” Poe v. Comm’r of Soc. Sec., 342 F. App’x 149, 155 (6th Cir. 2009); see also 20 C.F.R. §§ 404.1545(a), 416.945(a).Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to assess a claimant’s work abilities using medical and nonmedical evidence.
Kaplarevic v. Saul · filed 2020-07-16
The ALJ provided a narrative discussion of the medical and nonmedical evidence and assessed Plaintiff’s abilities in accordance with 20 C.F.R. § 404.1545 and SSR 96-8p.Read the full opinion on CourtListener →
Section 404.1545 requires a new residual functional capacity determination when the ALJ must reassess medical opinions, symptom statements, and lay witness statements.
Hansen v. Saul · filed 2020-08-26
Since the ALJ has been instructed to readdress the medical opinions in the record, Plaintiff’s symptom statements, and the statements of Plaintiff’s husband, a new RFC determination will be required. 20 C.F.R. § 404.1545.Read the full opinion on CourtListener →
An RFC assessment must consider all medically determinable impairments, whether severe or not.
(SS) Akin v. Commissioner of Social Security · filed 2020-09-01(a)(2)
A claimant's residual functional capacity (“RFC”) is “the most [a claimant] can still do despite [his] limitations.” 20 C.F.R. §§ 404.1545(a), 416.945(a); ... The ALJ must consider “all of [a claimant's] medically determinable impairments”—whether severe—when assessing a RFC. 20 C.F.R. §§ 405.1545(a)(2), 416.945(a)(2). ... However, as discussed above, Plaintiff fails to demonstrate fibromyalgia was a medically determinable impairment under SSR 12-p.Read the full opinion on CourtListener →
The ALJ determines residual functional capacity from the record; a formulation supported by substantial evidence need not match every limitation in a medical finding.
(SS) Dubord v. Commissioner of Social Security · filed 2021-06-02
The ALJ then cited to portions of the record in making this finding, which is sufficient to demonstrate that the RFC formulation is based on substantial evidence. Vertigan v. Halter, 260 F.3d 1044, 1049 (9th Cir. 2001) (“It is clear that it is the responsibility of the ALJ, not [a] physician, to determine residual functional capacity.”) (citing 20 C.F.R. § 404.1545).Read the full opinion on CourtListener →
The ALJ determines residual functional capacity and may formulate it from the record even when a medical finding states a different limitation.
(SS) Dubord v. Commissioner of Social Security · filed 2021-06-29
The ALJ then cited to portions of the record in making this finding, which is sufficient to demonstrate that the RFC formulation is based on substantial evidence. Vertigan v. Halter, 260 F.3d 1044, 1049 (9th Cir. 2001) (“It is clear that it is the responsibility of the ALJ, not [a] physician, to determine residual functional capacity.”) (citing 20 C.F.R. § 404.1545).Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can still do despite physical and mental limitations.
Thomas v. Commissioner of Social Security · filed 2021-09-03(a)
The RFC finding is the Administrative Law Judge’s ultimate determination of what a claimant can still do despite her physical and mental limitations.Read the full opinion on CourtListener →
Section 404.1545(c) requires the agency to consider mental limitations when assessing a claimant's residual functional capacity.
Tester v. Delia · filed 2014-10-21(c)
In determining a claimant's RFC, the agency must also consider mental capacity limitations.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to assess residual functional capacity in light of the claimant’s limitations, including supported mental limitations.
Bechtel v. Berryhill · filed 2020-06-08(a)(1)
Accordingly, for the reasons outlined above, the Court finds no error in fashioning the RFC and concludes that the ALJ duly considered Plaintiff’s mental impairments in the decision.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider all medically determinable impairments and relevant evidence when assessing a claimant’s residual functional capacity.
Noble v. Commissioner Social Security Administration · filed 2020-06-10
By failing to properly credit these opinions, the ALJ failed to incorporate all of Plaintiff's limitations into the RFC and, by extension, the dispositive hypothetical question posed to the VE.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to assess what a claimant can still do despite her limitations; an ALJ may omit an additional concentration, persistence, or pace restriction from the RFC when the evidence supports the explanation for doing so.
Leigh v. Berryhill · filed 2020-07-01(a)(1)
Accordingly, the ALJ did not err because substantial evidence supports the limitations that the ALJ both included and declined to include in his hypothetical question and RFC determination.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider relevant mental limitations when assessing residual functional capacity, but mild limitations need not appear as separate restrictions when the ALJ has considered them.
Deborah Kaye Banks v. Saul · filed 2020-11-25(a)(1)
Considering this exhaustive analysis and the ALJ’s repeated statements that she did so, Plaintiff has failed to show that the ALJ did not consider her mental limitations, in particular her depressive disorder, in fashioning the RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(1) measures residual functional capacity by what a claimant can do despite limitations, including supported mental limitations.
Ploetz v. Kijakazi · filed 2022-07-25(a)(1)
RFC is the most the claimant can do in a work setting “despite her limitations.” ... And while the ALJ did find that Ploetz would have trouble interacting with others due to her social anxiety, the ALJ accounted for this difficulty by limiting Ploetz to only occasional interaction with coworkers and supervisors, no tandem tasks, and no interaction with the general public. (Tr. 22.)Read the full opinion on CourtListener →
Residual functional capacity must account for limitations caused by a claimant’s mental impairments.
Collins v. Kijakazi · filed 2022-09-13(a)(1)
As for the upshot of the ALJ’s step two error, it cannot be argued that the error was harmless because Plaintiff’s mental impairments were not considered at step three, nor were their limitations encapsulated in the RFC.Read the full opinion on CourtListener →
Section 404.1545(c) does not require a supervisor interaction limit in a mental RFC when the record does not support one.
Petragnani v. Commissioner of Social Security · filed 2022-09-20(c)
However, the Court finds no merit in Plaintiff’s contention that the ALJ’s failure to include a limitation dealing with supervisors in Plaintiff’s RFC was error. There is only a single instance in the record in which Plaintiff references an issue with supervisors, and that issue concerned the pace of his work rather than an unwillingness to be supervised.Read the full opinion on CourtListener →
Section 404.1545 concerns functional limits on work; a mild impairment under the paragraph B criteria does not automatically require a corresponding RFC restriction.
Burnett v. Commissioner of Social Security · filed 2024-03-26
To start, Burnett improperly conflates (1) degrees of impairment in the paragraph B findings, see 20 C.F.R. § 404.1520a, with (2) functional limitations in an RFC, see 20 C.F.R. § 404.1545. ... Thus, even if the ALJ ignored—when formulating the RFC—his paragraph B finding of a mild impairment in Burnett’s ability to adapt or manage himself, there would be no error.Read the full opinion on CourtListener →
An ALJ must consider mental impairments when assessing residual functional capacity but need not include mental restrictions unsupported by the evidence.
Dovico v. Commissioner of Social Security · filed 2024-08-28(a)(2)
The ALJ discussed, in detail, the consultative evaluation of Dr. Khan (summarized above) but found it only partially persuasive and lacking in function analysis. This finding is supported by substantial evidence. The ALJ, then, was not obligated to include mental restrictions in Plaintiff’s RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(1) does not require an ALJ to copy a medical source’s moderate mental limitation into the RFC when the work restrictions adequately account for it.
Buckles v. Social Security Administration · filed 2024-09-30(a)(1)
The ALJ did not have to fashion an identical RFC limitation to match Dr. Padilla’s.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity must consider the relevant evidence and explain how the assessment accounts for moderate limitations in concentration, persistence, or pace.
Johnson v. O'Malley · filed 2024-12-09(a)(3)
Having considered the record, the medical evidence, plaintiff's hearing testimony, the ALJ's written decision, and the parties’ contentions, the Court finds that the ALJ failed to explain how the RFC accounts for plaintiff’s functional mental limitations considering her moderate limitations in concentration, persistence, or pace that the ALJ found at step three.Read the full opinion on CourtListener →
Concentration, persistence, and pace
Section 404.1545 requires an RFC assessment to account for a claimant’s moderate limitations in concentration, persistence, or pace with sufficient explanation.
Robbins v. Commissioner of Social Security · filed 2020-02-18
Contrary to the Commissioner’s argument, because the ALJ found a moderate limitation in concentration, persistence or maintaining pace, the ALJ is required to properly incorporate that limitation into the RFC with sufficient explanation. The ALJ failed to do so here.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to account for a claimant’s documented moderate limitations in concentration, persistence, and pace.
Seals v. Saul · filed 2020-04-07
Because the ALJ failed to include or account for plaintiff’s moderate limitations in concentration, persistence or pace in his RFC and hypothetical to the VE, the Court must reverse and remand this case to the SSA for further proceedings.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple and routine tasks can account for concentration, persistence, and pace limitations when the record supports that restriction.
Gonzalez v. Berryhill · filed 2020-04-15
Thus, like in Scott and Howard, the RFC’s use of a “simple and routine tasks” limitation was sufficient to capture Gonzalez’s concentration, persistence, and pace problems without “lay[ing] out the exact deficiencies with medical precision,” Scott, 855 F.3d at 858, or using “specific or symptomatic terms,” Howard, 255 F.3d at 582.Read the full opinion on CourtListener →
An RFC assessment must account for a claimant’s supported moderate limitations in concentration, persistence, and pace.
Goossens v. Saul · filed 2020-06-29
The ALJ’s decision must be reversed because the Court cannot determine whether the ALJ considered Plaintiff’s moderate limitations in concentration, persistence, and pace in formulating her RFC finding or her hypothetical question to the VE.Read the full opinion on CourtListener →
An RFC assessment does not require a slower work pace limitation merely because a claimant walks slowly.
Hobbs v. Saul · filed 2020-07-21(a)(2)
The court agrees with the ALJ that Hobbs is conflating mental and physical pace. Limitations regarding concentration, persistence, or pace are mental limitations and include actions such as an ability to carry out short and simple instructions or an ability to make simple work-related decisions. Someone who physically walks slow does not necessarily perform job duties at a slower pace.Read the full opinion on CourtListener →
An RFC may account for limitations in concentration, persistence, or pace when it addresses medical evidence about the claimant’s ability to stay on task.
Wood v. Berryhill · filed 2020-09-15(a)(1)
Rather, so long as the RFC directly addresses some form of medical evidence that speaks to the ability of a claimant to “stay on task,” it can satisfy the Social Security Act’s requirements.Read the full opinion on CourtListener →
An RFC assessment must account for moderate difficulties in concentration, persistence, or pace, or explain why no corresponding restriction is needed.
Harcharik v. Saul · filed 2020-10-28(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 →
An RFC may account for moderate limitations in concentration, persistence, and pace through specific work restrictions without using those exact terms.
Sporrer v. Saul · filed 2020-12-01
Taken together, these limitations were sufficient to encompass a moderate limitation in concentration, persistence, and pace. The ALJ was not required to specifically refer to “concentration, persistence, and pace” when articulating Sporrer’s RFC.Read the full opinion on CourtListener →
Section 404.1545 allows an RFC limiting a claimant to simple, routine, repetitive tasks in two-hour segments when that restriction accounts for limitations in concentration, persistence, and pace.
Buckner v. Saul · filed 2021-02-09(a)(1)
In sum, the ALJ did not err in accounting for Plaintiff’s limitations in concentration, persistence, and pace. The ALJ limited Plaintiff to an RFC of “simple, routine, and repetitive tasks” for two-hour segments at a time, which directly accounts for his limitations in concentration, persistence, and pace.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to account for a claimant’s limitations in concentration, persistence, and pace when the record supports them.
Rucker v. Saul · filed 2021-02-16(a)(2)
Limiting Rucker to performing simple, routine, and repetitive tasks did not adequately encompass a moderate limitation in concentration, persistence, and pace.Read the full opinion on CourtListener →
An RFC can account for moderate limitations in concentration, persistence, and pace through a restriction to simple, routine, repetitive tasks and unskilled work when the evidence supports that assessment.
Harris v. Commissioner of Social Security · filed 2021-03-17(a)(2)
The ALJ properly accounted for Plaintiff’s moderate limitations in concentration, persistence, and pace by incorporating in the RFC (and the hypothetical to the VE) the limitation of “simple, routine repetitive tasks,” Tr. at 34 (emphasis omitted), and finding Plaintiff can perform unskilled work, Tr. at 47.Read the full opinion on CourtListener →
Residual functional capacity may account for mental limitations through work restrictions supported by the evidence.
SEELEY v. SAUL · filed 2021-03-29(a)(1)
Accordingly, the Court finds the ALJ adequately accommodated Diane S.'s mental limits in his functional capacity finding and reasonably assessed her mental impairments.Read the full opinion on CourtListener →
A residual functional capacity restriction against production-rate pace can account for medical opinions calling for flexibility in time limits and production standards.
Washington v. Commissioner of Social Security · filed 2021-03-29(a)
The court concludes that the ALJ’s RFC did include the limitations suggested by Dr. Waggoner and Dr. Savitscus. The RFC limiting Plaintiff to tasks “not at a production rate pace” encompasses and extends beyond the limitations suggested by Dr. Waggoner and Dr. Savitscus that Plaintiff would need flexibility with time and production standards.Read the full opinion on CourtListener →
An RFC assessment must account for supported mental limitations, including limitations in pace; restrictions on production quotas and job stress can do so.
Armstrong v. Saul · filed 2021-03-24(a)(3)
And by excluding “fast-paced production quotas” and further limiting her to a “low-stress job,” the ALJ accounted for Armstrong’s limitations in the broad functional area of pace.Read the full opinion on CourtListener →
An RFC must account for a claimant’s moderate difficulties with concentration, persistence, and pace; limits to simple tasks and reduced pace may be insufficient when the vocational expert has not reviewed the medical record.
JOHNSON v. SAUL · filed 2021-03-25
But her RFC determination and corresponding hypothetical consisted of language the Seventh Circuit has found to be deficient when the VE has not reviewed the medical record.Read the full opinion on CourtListener →
An RFC determination must account for a claimant’s supported moderate limitation in concentration, persistence, or pace.
Walton v. Kijakazi · filed 2021-11-03
Finally, the ALJ’s RFC determination must account for his moderate limitation in maintaining concentration, persistence, or pace.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to account for difficulties with concentration, persistence, or pace, or explain why no corresponding limitation is needed.
Hawks v. Saul · filed 2022-02-01
The ALJ should also include an RFC limitation to address Plaintiff’s difficulties with concentration, persistence, or pace, or explain why a limitation is not needed.Read the full opinion on CourtListener →
Section 404.1545 allows an RFC limiting a claimant to simple, routine, repetitive work to account for mild concentration, persistence, or pace limitations when the ALJ explains why that limit is sufficient.
Riddle v. Commissioner of Social Security · filed 2022-03-28(a)
Here, as described above, the ALJ acknowledged and considered Riddle’s pain and PTSD, concluded he had mild difficulty persisting or maintaining pace, and then sufficiently explained why a limitation for simple, routine, and repetitive work accommodated Riddle’s limitations in mental functioning, including CPP.Read the full opinion on CourtListener →
An RFC limiting a claimant with moderate concentration, persistence, or pace limitations to simple, repetitive tasks must have substantial evidentiary support.
Weber v. Commissioner of Social Security · filed 2022-03-31(a)
Rather, substantial evidence must support an RFC determination that a plaintiff with moderate CPP limitations can perform simple, repetitive tasks.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to translate concentration and pace limitations into work restrictions supported by the medical evidence.
Smithey v. Saul · filed 2022-08-12(a)(3)
Like in Stubbs-Danielson, it appears the ALJ appropriately translated Plaintiff’s limitations with concentration and pace into “the only concrete restrictions available to him – the restrictions articulated by the State agency psychological consultants.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the physical and mental work a claimant can consistently perform despite limitations.
Needham v. Commissioner of Social Security · filed 2022-08-15(a)(1)
A claimant’s RFC is the level of physical and mental work he can consistently perform despite his limitations. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most activity a claimant can perform in a work setting despite limitations from impairments and related symptoms.
Shavers v. Commissioner of Social Security · filed 2022-08-16(a)(1)
A claimant’s RFC is the most activity that he can engage in a work setting despite the physical and mental limitations that arise from her impairments and related symptoms. 20 C.F.R. § 404.1545(a)(1); see also SSR 96-8p; Villano v. Astrue, 556 F.3d 558, 561–62 (7th Cir. 2009). ... Thus, the ALJ considered the entirety of the record and supported her RFC determination with substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the ALJ to consider mild mental impairments when assessing residual functional capacity, but does not require limitations that have no effect on the claimant’s ability to work.
Grunig v. Commissioner of Social Security · filed 2022-08-17(a)(2)
Given the absence of evidence that Petitioner’s mild mental impairments limited Petitioner’s ability to perform any work-related activities, the ALJ was not required to include additional mental limitations in his RFC assessment or hypothetical to the VE.Read the full opinion on CourtListener →
An ALJ may determine residual functional capacity from medical and other record evidence even when the result does not fully align with the medical opinions.
Smith v. Commissioner of Social Security · filed 2022-08-17(a)(3)
Initially, the ALJ was acting well within his statutory authority when he considered the medical and other evidence in the record to reach an RFC determination that did not fully align with the proffered medical opinions.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can do in a work setting despite physical and mental limitations.
Franke v. Commissioner of Social Security · filed 2022-08-22(a)
A disability claimant's RFC describes the maximum he can do in a work setting despite her mental and physical limitations. 20 C.F.R. § 404.1545(a). ... The Court finds, after review of the entire administrative record, finds the ALJ’s decision was supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite physical and mental limitations from impairments.
Schott v. Commissioner of Social Security · filed 2022-08-23(a)
A plaintiff’s RFC “is defined as the most a [plaintiff] can still do despite the physical and mental limitations resulting from her impairments.” Poe v. Comm’r of Soc. Sec., 342 F.App’x 149, 155 (6th Cir. 2009). See also 20 C.F.R. §§ 404.1545(a), 416.945(a).Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires residual functional capacity to reflect the most a claimant can still do despite limitations, based on relevant evidence.
Arroyo v. Kizakazi · filed 2022-08-23(a)(1)
The purpose of the RFC analysis is to evaluate based on relevant evidence “the most [a claimant] can still do despite [her] limitations.” See 20 C.F.R. § 404.1545(a)(1). I find the ALJ reasonably construed the evidence of record.Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can do despite limitations, even if doing it is not pain free.
(SS) Michelle Garrett v. Commissioner of Social Security · filed 2022-08-24(a)(1)
Although persistent pain at a level of 4 to 6 out of 10 with medication is still a considerable amount of pain to deal with on a chronic basis, the RFC is not the most one can do while remaining pain free. It is the most one can do despite one’s limitations. 20 C.F.R. §§ 404.1545(a)(1).Read the full opinion on CourtListener →
A residual functional capacity assessment must account for the claimant’s full range of supported limitations in concentration, persistence, and pace.
Anderson v. O'Malley · filed 2023-12-06
An RFC assessment must account for a plaintiff’s full range of limitations related to concentration, persistence, and pace.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; an RFC restriction on production paced jobs can account for moderate limitations in concentration, persistence, or pace.
Passwaters v. Kijakazi · filed 2024-09-25(a)(1)
A claimant’s RFC is “the most [they] can still do despite [their] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a). ... While the RFC did not adequately account for Plaintiff’s moderate CPP difficulties by accommodating for time off task with normal scheduled breaks, the RFC did account for Plaintiff’s CPP issues by precluding him from performing “production paced jobs.”7 Tr. 22.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to explain how relevant limitations affect a claimant’s ability to stay on task.
Outlaw v. Kijakazi · filed 2025-03-06(a)(1)
A claimant’s RFC is “the most [they] can still do despite [their] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a). ... ThisCourt agrees that the ALJ committed reversible error by failing to explain how, despite Plaintiff’s moderate limitations in concentration, persistence, and pace (“CPP”), he could stay on task for at least eighty percent of the workday.Read the full opinion on CourtListener →
An RFC limiting a claimant to simple work must address whether the claimant can sustain that work when the evidence shows limitations in persistence.
Clay v. Commissioner of Social Security · filed 2025-06-04(a)(1)
The RFC is a measure of what an individual can do despite his limitations. Young v. Barnhart, 362 F.3d 995, 1000–01 (7th Cir. 2004); 20 C.F.R. § 404.1545(a)(1). ... These limitations and the explanations fail to address the durational aspect of CPP. Although the ALJ recognized the Plaintiff’s limitations with respect to concentration and persistence and she limited the Plaintiff to “simple work,” the ALJ did not address whether the Plaintiff could do the “simple work” persistently—such as throughout a normal workday or workweek in light of the Plaintiff’s monthly cycles of insomnia followed by lethargy and problems completing tasks. This is an error that requires remand.Read the full opinion on CourtListener →
Notes 4051–4200 of 6,798, oldest cases first.
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