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.
Exertional and nonexertional limits
An ALJ’s residual functional capacity assessment should use all relevant evidence and consider the claimant’s physical, mental, sensory, and other work requirements.
Sanford v. Commissioner of the Social Security Administration · filed 2020-02-11(a)(3) and (4)
An ALJ’s RFC assessment should be based on all relevant evidence and will consider the claimant’s ability to meet the physical, mental, sensory, and other requirements of work. 20 C.F.R. § 404.1545(a)(3) and (4).Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider nonexertional impairments alongside exertional impairments.
Robertson v. Commissioner of Social Security · filed 2020-03-10
The regulations also provide that, if a claimant suffers from a nonexertional impairment as well as an exertional impairment, both are considered in determining her residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of both exertional and nonexertional impairments when determining residual functional capacity.
Scharmer v. Commissioner of Social Security · filed 2020-04-14
The regulations also provide that if a claimant suffers from a ... nonexertional impairment as well as an exertional impairment, both are considered in determining his residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of both exertional and nonexertional impairments when determining residual functional capacity.
Smalley v. Commissioner of Social Security · filed 2020-07-10
The regulations also provide that, if a claimant suffers from a nonexertional impairment as well as an exertional impairment, both are considered in determining her residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945.Read the full opinion on CourtListener →
Residual functional capacity must account for non-exertional impairments as well as exertional impairments.
Centeno v. Commissioner of Social Security · filed 2021-06-14
The regulations also provide that if a claimant suffers from a non-exertional impairment as well as an exertional impairment, both are considered in determining his residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945. ... In short, the ALJ sufficiently accounted for Plaintiff’s non-exertional impairments and limitations in her RFC assessment.Read the full opinion on CourtListener →
Section 404.1545 requires both exertional and nonexertional impairments to be considered when determining residual functional capacity.
Garmhausen v. Commissioner of Social Security · filed 2022-02-14
The regulations also provide that if a claimant suffers from a nonexertional impairment as well as an exertional impairment, both are considered in determining her residual functional capacity.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of both exertional and nonexertional impairments when determining residual functional capacity.
Johnson v. Commissioner of Social Security · filed 2022-03-14
The regulations also provide that, if a claimant suffers from a nonexertional impairment as well as an exertional impairment, both are considered in determining residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945.Read the full opinion on CourtListener →
Pain and other symptoms
An RFC assessment accounts for limitations caused by symptoms such as pain.
Harms v. Social Security Administration Commissioner · filed 2022-08-01(a)(3)
Limitations resulting from symptoms such as pain are also factored into the assessment. 20 C.F.R. § 404.1545(a)(3).Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires limitations caused by symptoms such as pain to be factored into a claimant’s residual functional capacity assessment.
Wolfe v. Social Security Administration Commissioner · filed 2022-07-27(a)(3)
Limitations resulting from symptoms such as pain are also factored into the assessment. 20 C.F.R. § 404.1545(a)(3).Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider the claimant’s descriptions of symptoms and limitations alongside the other relevant evidence.
Pipkins v. Kijakazi · filed 2022-01-25(a)
Accordingly, when determining a claimant’s RFC, the ALJ must evaluate the consistency of the claimant’s subjective statements of symptoms with the evidence of record.Read the full opinion on CourtListener →
Section 404.1545 requires residual functional capacity to be assessed from medical and other evidence about a claimant’s physical and mental abilities, including testimony about pain.
Lynn v. Schweiker · filed 1983-03-09
Under the regulations, the administrative law judge assesses the claimant’s “residual functional capacity” based on medical and other evidence as to the claimant’s physical and mental abilities. He then combines this assessment with information on the claimant’s age, education, and previous work experience in order to determine whether the claimant is capable of other work available in the national economy. 20 C.F.R. §§ 404.1545, 1546, 1560, 1561. ... Thus, the administrative law judge was in error in failing to consider the Plaintiff’s testimony. In addition, his finding that the Plaintiff is capable of light and sedentary work is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of subjective evidence of nonexertional ailments when assessing residual functional capacity.
Clemon J. JAMES, Plaintiff-Appellant, v. Otis W. BOWEN, Secretary of Health and Human Services, Defendant-Appellee · filed 1986-06-18
The AU must consider subjective evidence of nonexertional ailments, such as pain, which may have a disabling effect. ... See 20 C.F.R. §§ 404.1545 and 416.945.Read the full opinion on CourtListener →
Section 404.1545 permits pain to be considered when assessing residual functional capacity.
Szwandrok v. Bowen · filed 1987-04-28
Pain can be a factor in determining residual functional capacity. 20 C.F.R. § 404.1545. ... Consequently, the AU’s rejection of pain as a factor in determining plaintiff’s residual functional capacity is affirmed since the AU properly determined that no medical evidence demonstrated the cause of plaintiff’s pain.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment at steps four and five that accounts for an impairment’s effects, including limitations caused by pain, on the ability to perform past or other work.
Morin v. Secretary of Health & Human Services · filed 1992-04-10
At Steps 4 and 5 of the analysis;, an RFC assessment is necessary to determine the effects of claimant’s impairment,, including additional limitations imposed by¡ pain, on claimant’s capacity to perform forjner work or other work.Read the full opinion on CourtListener →
Section 404.1545 requires full consideration of pain and psychological impairments when assessing residual functional capacity.
McDonald v. Richard Schweiker, Secretary of Health and Human Services · filed 1983-01-26(c), (d)
Pain and psychiatric problems are both nonexertional impairments. Id.; see 20 C.F.R. § 404.1545(c), (d). If an individual has a combination of exertional and nonexertional impairments, as McDonald does, the nonexertional impairments must be given full consideration.Read the full opinion on CourtListener →
Section 404.1545(e) recognizes that pain can limit functioning beyond what objective medical abnormalities alone would suggest.
Johnson v. Shalala · filed 1995-07-27(e)
Yet despite the inability to measure it objectively, it can have “severe debilitating effects” — even to the point of disabling a person who does not meet or equal the impairments listed in Appendix 1 and who would not objectively be expected to experience pain to the degree subjectively expressed. 20 C.F.R. § 404.1545(e) (“pain or other symptoms may cause a limitation of function beyond ... the anatomical, physiological or psychological abnormalities considered alone”); Fair, 885 F.2d at 601.Read the full opinion on CourtListener →
Section 404.1545(a) permits an ALJ to consider symptoms, subjective complaints, observations by others, and medical records when assessing residual functional capacity, and to discount complaints found exaggerated.
Thurn v. Apfel · filed 1998-01-07(a)
In determining a claimant’s residual functional capacity, the ALJ is entitled to consider the following factors: the claimant’s symptoms, subjective complaints that go beyond the symptoms, observations by others including family members and medical personnel, and the claimant’s medical records. 20 C.F.R. § 404.1545(a). ... Because of these reasons (and the reasons discussed more fully in the section on plaintiffs credibility), I find that the ALJ’s determination that plaintiffs subjective complaints were exaggerated is supported by substantial evidence and the ALJ was therefore entitled to discount plaintiffs subjective complaints in determining plaintiffs residual functional capacity.Read the full opinion on CourtListener →
Section 404.1545 requires residual functional capacity to be determined from all relevant evidence, including complaints of pain and fatigue.
Knapp v. Apfel · filed 1998-07-10
The RFC is determined by considering all relevant evidence, consisting, inter alia, of symptoms including pain. See 20 C.F.R. §§ 404.1545, 416.945; Urtz, 965 F.Supp. at 326. Thus, the ALJ had an affirmative obligation to consider plaintiffs pain and fatigue complaints when determining whether plaintiff could perform a certain category of work.Read the full opinion on CourtListener →
Section 404.1545 requires pain to be considered when determining residual functional capacity.
Ricketts v. Apfel · filed 1998-08-14
The federal regulations which guide the determination of RFC specifically mention pain, and Williams includes pain as a nonex-ertional limitation. 20 C.F.R. § 404.1545; 844 F.2d at 752 (citing Channel v. Heckler, 747 F.2d 577, 580 (10th Cir.1984)). To the contrary, the ALJ found no nonexertional limitations. (R. at 24.) This further indicates the ALJ did not intend the VE to include pain in her assessment, producing a flawed hypothetical.Read the full opinion on CourtListener →
Sleep disruptions require review under § 404.1545(e) when the record suggests they amount to a limitation.
Princeau v. Chater · filed 1997-12-10(e)
nothing in the record suggests that the alleged disruptions rise to the level of a limitation requiring review under 20 C.F.R. § 404.1545(e).Read the full opinion on CourtListener →
An ALJ must consider how a claimant’s symptoms limit each relevant function before determining residual functional capacity.
Lewis v. Apfel · filed 1999-04-22(a)
The magistrate judge also found that the ALJ failed to provide substantial evidence for his conclusion that her subjective symptoms were not totally disabling, and advised that on remand, the ALJ should consider each relevant function separately and determine whether it is limited in light of Plaintiffs subject symptoms before making a final determination regarding Plaintiffs residual functional capacity. This Court finds no error in Magistrate Judge Smith’s analysis or prescriptions and accordingly adopts the Report-Recommendation in its entirety for the reasons stated therein.Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can do despite her impairments, including limitations caused by pain.
Kinney v. SSA · filed 2002-06-20(a)
To make this determination, the ALJ must assess both the claimant’s residual functional capacity (“RFC”), that i s , what the claimant can do despite her impairments, and the demands of the claimant’s prior employment. ... The medical evidence in the record supports the ALJ's determination that Kinney's pain did not limit her functional capacity beyond that already assessed.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider a claimant’s symptoms, signs, laboratory findings, and other evidence when assessing residual functional capacity.
Gagnon v. Barnhart · filed 2002-07-01
In assessing an individual’s RFC, the ALJ is to consider his symptoms (such . as pain), signs and laboratory findings together with the other evidence. See 20 C.F.R. § 404.1545.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment based on all relevant evidence, including testimony about pain and other non-exertional limitations.
Brown v. Barnhart · filed 2004-01-26(a)(1)
On remand, the ALJ must also consider plaintiffs testimony concerning pain and other non-exertional limitations in determining RFC.Read the full opinion on CourtListener →
Section 404.1545(e) recognizes that pain can affect the work capacity of people with the same disorder differently.
Ynocencio v. Barnhart · filed 2004-01-27(e)
The regulations, recognize that pain causes a disorder commonly associated with disc problems to affect individuals differently: “someone with a low back disorder may be fully capable of the physical demands consistent with those of sustained medium work activity, but another person with the same disorder, because of pain, may not be capable of more than the physical demands consistent with those of light work activity on a sustained basis.” 20 C.F.R. § 404.1545(e). When assessing symptoms as subjective as pain, it is imperative that the ALJ consider the evidence provided by treating sources and give their opinions as much weight as possible, even if not controlling weight.Read the full opinion on CourtListener →
Section 404.1545(a) requires the residual functional capacity assessment to account for the claimant’s pain alongside physical and mental impairments.
Porcher v. Barnhart · filed 2005-07-12(a)
Nevertheless, and because the case will be remanded in any event, the ALJ should make an explicit finding regarding the degree of pain suffered by plaintiff and how that, factored into the analysis along with the physical and mental impairments of plaintiff, impacts, if at all, the RFC determination at step five.Read the full opinion on CourtListener →
Residual functional capacity may differ between people with the same severe impairment because of their other impairments, pain, and symptoms.
Griffeth v. Commissioner of Social Security · filed 2007-02-09(e)
The regulations recognize that individuals who have the same severe impairment may have different RFCs depending on their other impairments, pain, and other symptoms. 20 C.F.R. § 404.1545(e).Read the full opinion on CourtListener →
When assessing residual functional capacity for a claimant with fibromyalgia, the ALJ must consider subjective pain and its effect on the claimant’s ability to work rather than rely on a lack of confirming objective medical evidence.
Davila v. Commissioner of Social Security · filed 2014-01-28(a)(3)
In light of this severe impairment, ALJ Jarvis was required to concentrate her inquiry into Plaintiffs residual functional capacity on Plaintiffs subjective complaints of pain and limitation and how that would limit Plaintiffs ability to work. However, ALJ Jarvis instead chose to focus her assessment on the lack of confirming objective medical evidence. This is an error.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires a residual functional capacity assessment to consider relevant evidence of limitations caused by pain.
Bud Gaskin v. Commissioner of Social Security · filed 2013-08-14(a)(1)
The ALJ failed to address Dr. Duffin’s assessment that Gaskin’s pain was often severe enough to interfere with his attention and concentration, and those limitations were not included in the ALJ’s residual functional capacity assessment or hypothetical questions.Read the full opinion on CourtListener →
An RFC assessment must account for medical evidence that persistent pain limits a claimant’s ability to sit.
Drinnin v. Colvin · filed 2015-01-09(a)(1)
The ALJ improperly discounted Dr. Diem-er’s finding that plaintiff suffered from persistent pain that precluded sitting.Read the full opinion on CourtListener →
Residual functional capacity reflects the most a claimant can do despite limitations, including the effects of episodic symptoms.
Ellison v. Berryhill · filed 2017-06-23
Thus, the court finds that, given the inconsistencies discovered in the record, the ALJ appropriately considered the physical effects of Plaintiff’s flares on his ability to work when determining his RFC.Read the full opinion on CourtListener →
An RFC assessment must account for limitations caused by symptoms, and the record needs further development when new symptoms have not been assessed for their effect on the claimant’s ability to function.
Keiter v. Social Security Administration Commissioner · filed 2018-01-02(a)(3)
Limitations resulting from symptoms such as pain are also factored into the assessment. 20 C.F.R. § 404.1545(a)(3). ... The record revealed that both non-examining medical consultants completed RFC assessments prior to September of 2014, and that no medical professional opined as to how these new symptoms might impact Plaintiff’s ability to function. After reviewing the record, Court believes remand is necessary for the ALJ to more fully and fairly develop the record regarding Plaintiff’s physical RFC.Read the full opinion on CourtListener →
An RFC assessment must account for limitations caused by symptoms such as pain.
Rudder v. Social Security Administration Commissioner · filed 2018-08-27(a)(3)
Limitations resulting from symptoms such as pain are also factored into the assessment. 20 C.F.R. § 404.1545(a)(3).Read the full opinion on CourtListener →
Section 404.1545(e) requires the ALJ to consider medication side effects and pain when determining a claimant’s residual functional capacity.
O'Brien v. Berryhill · filed 2020-03-11(e)
The ALJ is obligated to consider medication side effects and pain in determining a claimant’s RFC. See 20 C.F.R. § 404.1529(c)(3); SSR 16-3P, 2017 WL 5180304, at *8 (S.S.A. Oct. 25, 2017); see also 20 C.F.R. § 404.1545(e).Read the full opinion on CourtListener →
Residual functional capacity must account for functional limitations caused by chronic pain.
Roberts v. Commissioner of Social Security · filed 2020-03-18
Finally, while the ALJ found Ms. Roberts’ fibromyalgia to be a severe impairment and found her capable of light work, she did not provide any functional limitations that accommodated her chronic pain symptoms.Read the full opinion on CourtListener →
Section 404.1545(a)(4) requires the ALJ to consider mental limitations when assessing residual functional capacity.
(SS) Martin v. Commissioner of Social Security · filed 2020-03-19(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). Here, the undersigned concludes that the RFC, which included no mental limitations despite a record clearly indicative of limiting mental impairments, was not grounded in substantial evidence, and that the error was not harmless.Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC assessment to consider all relevant evidence and the combined effects of all impairments, including those that are not severe.
Wandick v. Commissioner of Social Security · filed 2020-11-25(a)
In order to properly determine plaintiff’s RFC to work, the ALJ was required to consider all of the relevant evidence as well as the combined effects of all of plaintiff's impairments, even those not found to be severe.Read the full opinion on CourtListener →
Section 404.1545(a)(3) permits consideration of a claimant’s descriptions of limitations caused by symptoms such as pain when assessing residual functional capacity.
Brock v. SSA · filed 2021-01-28(a)(3)
Further, “relevant . . . other evidence” may be assessed when determining RFC, including “descriptions and observations of [claimant’s] limitations from [claimant’s] impairment(s), including limitations that result from [claimant’s] symptoms, such as pain” provided by the claimant. Id. § 404.1545(a)(3). ... The ALJ clearly evaluated Plaintiff’s complaints of pain, but found them unpersuasive due to Plaintiff’s lack of credibility.Read the full opinion on CourtListener →
An ALJ must consider a claimant’s impairments and related symptoms, including pain, when assessing exertional and non-exertional capacity.
WARD v. SAUL · filed 2021-02-02(b)
An ALJ must determine a claimant’s exertional and non-exertional capacity only after considering all of a claimant’s impairments, as well as any related symptoms, including pain. See Hines, 453 F.3d at 562–63; 20 C.F.R. § 404.1545(b).Read the full opinion on CourtListener →
Section 404.1545(b) requires an ALJ to consider a claimant’s impairments and related symptoms, including pain, when assessing physical capacity.
ENGLISH v. SAUL · filed 2021-02-22(b)
An ALJ must determine a claimant’s exertional and non-exertional capacity only after considering all of a claimant’s impairments, as well as any related symptoms, including pain.Read the full opinion on CourtListener →
In assessing residual functional capacity, an ALJ must consider all relevant medical and other evidence, including the claimant’s subjective complaints of pain.
Lupe v. Commissioner of Social Security · filed 2021-02-26(a)(3)
In assessing a claimant’s RFC, an ALJ must consider “all of the relevant medical and other evidence,” including a claimant’s subjective complaints of pain. Id. § 404.1545(a)(3).Read the full opinion on CourtListener →
An RFC assessment may account for migraine headaches through restrictions on exposure to potential triggers.
Boyd v. Commissioner of Social Security · filed 2021-07-27(a)(1), (a)(3)
While it is undisputed that Plaintiff suffers from migraines, Plaintiff’s RFC successfully accommodates such impairment. Notably, the RFC includes that Plaintiff “must avoid concentrated exposure to extreme temperatures, excessive noise, excessive vibration, and pulmonary irritants such as fumes, odors, dust, gases, and poorly ventilated areas” (Tr. 20).Read the full opinion on CourtListener →
Section 404.1545(e) requires the ALJ to consider chronic pain when assessing a claimant’s residual functional capacity for sustained, full-time work.
Tometczak v. Kijakazi · filed 2021-10-20(e)
Although the ALJ properly discounted Dr. Smiley’s listing opinion because pain alone is not an adequate basis for equaling a listing, chronic pain must be considered by the ALJ ... when assessing a claimant’s RFC for sustained, full-time work at step five.Read the full opinion on CourtListener →
Section 404.1545(b) requires an ALJ to consider a claimant’s impairments and related symptoms, including pain, when determining exertional and non-exertional capacity.
PATTERSON v. KIJAKAZI · filed 2022-01-10(b)
An ALJ must determine a claimant’s exertional and non-exertional capacity only after considering all of a claimant’s impairments, as well as any related symptoms, including pain. See Hines, 453 F.3d at 562–63; 20 C.F.R. § 404.1545(b).Read the full opinion on CourtListener →
An ALJ may account for migraine headaches in a residual functional capacity assessment through limitations supported by the record.
Stout v. Commissioner of Social Security · filed 2022-06-13(e)
Thus, the Court finds that the ALJ properly accounted for Plaintiff’s migraine headache impairments in the RFC as evinced by his assessment of the evidence related to the impairment and his inclusion of with specifically tailored RFC limitations. Moreover, because the limitations assessed by the ALJ are directly related to the evidence of record, the Court finds that the ALJ’s RFC determinization is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(3) treats a claimant’s subjective complaints as one of several factors in assessing residual functional capacity.
Gabel v. Social Security Administration, Commissioner of · filed 2022-06-29(a)(3)
A claimant’s subjective complaints are but one of many factors an ALJ is to consider when making the RFC finding. See 20 C.F.R. § 404.1545(a)(3).Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider a claimant’s symptoms when determining residual functional capacity, while including only limitations supported by the record.
Walker v. Saul · filed 2022-08-02
As applied here, the ALJ found Plaintiff’s complaints of fatigue, dizziness, and difficulty in handling stress not as limiting as Plaintiff suggested, such that the ALJ did not include specific limitations from those symptoms in the RFC. The ALJ properly made this determination based on several factors.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to consider a claimant’s impairments and explain how they affect relevant work functions when assessing residual functional capacity.
Briscoe v. Kijakazi · filed 2022-08-05(a)
Pursuant to 20 C.F.R. § 404.1545(a)(1), a claimant’s RFC captures her ability to do physical and/or mental work activities for a sustained period of time, given her limitations. An ALJ must “consider all of the claimant’s ‘physical and mental impairments, severe and otherwise, and determine, on a function-by-function basis, how they affect [his] ability to work.’” Thomas v. Berryhill, 916 F.3d 307, 311 (4th Cir. 2019) (quoting Monroe v. Colvin, 826 F.3d 176, 188 (4th Cir. 2016)); see also 20 C.F.R. § 404.1545(a)(2); SSR 96-8p, 61 Fed. Reg. 34,474, 34,475 (July 2, 1996). ... Here, the ALJ did not articulate that her RFC assessment was rooted in a function-by-function analysis of how Plaintiff’s impairments impacted his ability to work.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do in a work setting despite limitations; an unsupported limitation need not be included.
Alexander-Bond v. Kijakazi · filed 2022-08-08(a)(1)
The RFC is “the most a person can do in a work setting despite the person’s limitations.” Jeske v. Saul, 955 F.3d 583, 593 (7th Cir. 2020) (citing 20 C.F.R. § 404.1545(a)(1)). ... As such, more than a mere scintilla of evidence supports the ALJ’s analysis of Kameka’s migraines and his decision to exclude a limitation for Kameka’s migraines in the RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most work a claimant can perform despite her limitations.
McSwine v. Commissioner of Social Security · filed 2022-08-09(a)(1)
A claimant’s RFC is the maximum work that she can perform despite any limitations. See 20 C.F.R. § 404.1545(a)(1); SSR 96-8p, at *1-2.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider the combined effects of a claimant’s limitations and the relevant evidence of what the claimant can still do.
Rhodes v. Kijakazi · filed 2022-08-09
A claimant’s RFC is the most an individual can do despite the combined effects of his credible limitations. See 20 C.F.R. § 404.1545. ... Despite Plaintiff's hearing testimony that her mental impairments would preclude her from working, substantial medical evidence supports the ALJ's RFC determination.Read the full opinion on CourtListener →
Section 404.1545(c) requires a mental RFC assessment supported by evidence of how mental impairments affect the claimant’s ability to work.
Jordan v. Commissioner of Social Security · filed 2022-08-09(c)
Because the ALJ appears to reject the findings of the only examining mental health expert and points to no other objective medical evidence in the record supporting her RFC determination, and because the Court does not find that objective medical evidence supporting the mental RFC otherwise exists in the record, the Court concludes the ALJ’s RFC determination is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an RFC assessment to account for limitations caused by symptoms; evidence of those limitations can require reconsideration of an ALJ’s RFC finding.
Parmenter, Jr. v. Social Security Administration Commissioner · filed 2022-08-04(a)(3)
Limitations resulting from symptoms such as pain are also factored into the assessment. 20 C.F.R. § 404.1545(a)(3). ... Accordingly, the Court finds substantial evidence does not support the ALJ’s decision, and the case must be reversed and remanded to allow the ALJ to further develop the record and further consider Plaintiff’s maximum RFC.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to consider relevant evidence of a claimant’s symptoms when assessing residual functional capacity.
Semidey v. Commissioner of Social Security · filed 2022-09-26(a)(3)
Indeed, the decision does not reflect that the ALJ appropriately considered Plaintiff’s subjective complaints or factored any of them into the RFC even though Plaintiff consistently and repeatedly complained of dizziness, weakness, fatigue, and side effects from medication.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ assessing residual functional capacity to consider a claimant’s subjective symptoms, including pain and reported limitations, alongside objective evidence.
Hagopian v. Commissioner of Social Security · filed 2023-02-28
In determining a claimant’s RFC, the ALJ must consider, in addition to the objective evidence, the claimant’s “subjective symptoms,” including “pain and descriptions of other limitations.” Lisa R. v. Comm’r of Soc. Sec., No. 18-cv-763, 2020 WL 210273, at *4, 2020 U.S. Dist. LEXIS 5796, at *11 (N.D.N.Y. Jan. 14, 2020) (citing 20 C.F.R. §§ 404.1545, 416.945).Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess greater limitations than medical opinions identify when the RFC accounts for those opinions and the claimant’s subjective complaints.
Cardin v. Commissioner of Social Security · filed 2023-03-01(a)
In doing so, the ALJ properly fashioned an RFC that considered the consultative opinions, but ultimately assessed greater limitations based upon plaintiff’s testimony.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an ALJ to consider a claimant’s reported symptoms when assessing residual functional capacity; failing to address material symptoms can require remand.
Ortiz v. Social Security Administration · filed 2023-06-02(a)(3)
An ALJ evaluates a claimant’s reported symptoms as part of the process for determining the claimant’s RFC. 20 C.F.R. §§ 404.1545(a)(3), 404.1529(a). ... The ALJ’s omission of any discussion of Plaintiff’s reported hand symptoms was legal error because the ALJ failed to provide any “specific reasons for the weight” he assigned to Plaintiff’s hand symptoms when he formulated the RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an RFC assessment to account for a claimant’s subjective symptom testimony; improperly discounting that testimony requires reconsideration of the RFC.
Aguilera v. Commissioner of the Social Security · filed 2023-06-22(a)(3)
The RFC assessment is dependent, in part, on Plaintiff’s subjective symptom testimony. ... Because the Court found that the ALJ erred in discounting Plaintiff’s subjective symptom testimony and that this error is not harmless, the ALJ, on remand, also must reconsider the RFC determination.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider how medically determinable impairments and their symptoms limit a claimant’s ability to work.
Castro Campos, Carlos v. Kijakazi, Kilolo · filed 2023-07-17
Residual functional capacity, or RFC, is the most a claimant can do despite his impairments and limitations. 20 C.F.R. § 404.1545; SSR 96-8p. In determining a claimant’s RFC, the ALJ considers the limiting effects of medically determinable impairments and any symptoms caused by those impairments, including pain. Id. ... But, as Campos persuasively argues, it is impossible to tell what limits the ALJ thought the migraines caused or how they affected Campos’s ability to perform basic work-related tasks because the ALJ did not make any specific findings on this issue.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to account for limitations supported by the record, including those arising from a claimant’s symptoms.
Vazquez v. Commissioner of Social Security · filed 2023-07-26(a)(1)
The ALJ included the limitations in the RFC that she found supported by the record to account for Plaintiff’s subjective complaints regarding the hidradenitis suppurativa.Read the full opinion on CourtListener →
An RFC assessment must consider all medically determinable impairments, including those that are not severe, and their combined limiting effects.
Smith v. Commissioner of Social Security · filed 2023-07-28(a)(2)
In rendering the RFC, therefore, the ALJ must consider the medical opinions in conjunction with all the other evidence of record and will consider all the medically determinable impairments, including impairments that are not severe, and the total limiting effects of each.Read the full opinion on CourtListener →
An ALJ may account for a claimant’s subjective complaints in the residual functional capacity assessment without fully crediting them.
(SS) Diaz v. Commissioner of Social Security · filed 2023-08-23(a)
Moreover, the Court notes that, while the ALJ ultimately declined to fully credit Plaintiff’s subjective complaints, the ALJ considered them in formulating the RFC, for example, by limiting Plaintiff to “reduced standing and/or walking to 4 hours.” (A.R. 20).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite physical or mental limitations; supported environmental restrictions can account for migraines.
Herdman v.Kijakazi · filed 2023-12-08(a)(1)
A claimant’s RFC is the most the claimant can do despite her physical or mental limitations. See 20 C.F.R. § 404.1545(a)(1). ... Here, Plaintiff’s RFC includes migraine-related limitations, hence Plaintiff’s first argument is without merit.Read the full opinion on CourtListener →
An ALJ must reassess residual functional capacity when an improper evaluation of the claimant’s symptoms calls the assessed capacity into question.
(SS)Espinosa v. Commissioner of Social Security · filed 2024-02-28(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); 20 C.F .R. § 416.945(a). ... Here, the ALJ improperly considered Plaintiff’s symptom claims, which calls into question whether the assessed RFC, and resulting hypothetical propounded to the vocational expert, are supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(e) requires the ALJ to consider an impairment’s limiting effects when determining residual functional capacity; consideration of the relevant evidence about sitting, standing, and walking satisfied that requirement here.
Hedlund v. O'Malley · filed 2024-03-06(e)
Because the ALJ properly considered all relevant factors and the medical evidence in the record in determining Plaintiff’s RFC—including evidence on her ability to sit, stand, or walk—her challenge to the RFC on this ground fails.Read the full opinion on CourtListener →
Section 404.1545(e) requires the ALJ to consider the limiting effects of all impairments when determining residual functional capacity, including impairments that are not severe.
Forbes v. O'Malley · filed 2024-03-07(e)
An ALJ must consider all relevant evidence in the record to fashion a plaintiff’s RFC, “including medical records, observations of treating physicians and others, and [the plaintiff’s] own description of [their] limitations.” Anderson v. Shalala, 51 F.3d 777, 779 (8th Cir. 1995); see also 20 C.F.R. § 404.1545(e) (providing that the ALJ “will consider the limiting effects of all [a plaintiff’s] impairment(s), even those that are not severe, in determining [their] residual functional capacity”). ... Because the ALJ properly considered all relevant factors and the medical evidence in the record in determining Plaintiff’s RFC—including evidence on his ability to stand or walk despite his back, knee, and chronic pain—the Court finds the ALJ reached a conclusion supported by the evidence.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite limitations; an assessment supported by substantial evidence may be sustained.
Walsh v. Kijakazi · filed 2024-03-08(a)(1)
A person’s “residual functional capacity” is “the most [the person] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... This Court finds no error in Judge Netburn’s analysis, and concludes that the ALJ’s RFC determination is supported by substantial evidence.Read the full opinion on CourtListener →
An ALJ need not include every limitation from a medical opinion in the residual functional capacity, even when the ALJ finds the opinion persuasive.
Adams v. Commissioner of Social Security · filed 2024-03-08
First, an RFC need not perfectly mirror any opinion–even an opinion that the ALJ finds persuasive.Read the full opinion on CourtListener →
An RFC determination must consider all relevant evidence, including medical diagnoses, treatment, observations, and opinions.
Hernandez v. O'Malley · filed 2024-03-11
An RFC determination must be based on all of the relevant evidence, including the diagnoses, treatment, observations, and opinions of medical sources, such as treating and examining physicians. 20 C.F.R. § 404.1545.Read the full opinion on CourtListener →
Section 404.1545(a)(4) requires the ALJ to assess a claimant’s ability to meet the physical, mental, sensory, and other requirements of work when formulating residual functional capacity.
Treadway v. Social Security Administration, Commissioner · filed 2024-03-11(a)(4)
As previously discussed, at step four of the sequential analysis the ALJ formulates a claimant’s RFC by assessing his or her “ability to meet the physical, mental, sensory, and other requirements of work.” 20 C.F.R. § 404.1545(a)(4).Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite limitations, and the ALJ’s assessment must have substantial evidentiary support.
Whitson v. Social Security Administration, Commissioner · filed 2024-03-12(a)(1)
The claimant’s RFC represents “the most [he or she] can still do despite [their] limitations.” Id. at § 404.1545(a)(1). ... Accordingly, the Court finds the evidence that Whitson cites in support of her argument does not sustain a different ruling, and that the record substantially supports the ALJ’s RFC finding.Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ to base a claimant’s residual functional capacity on all relevant evidence in the record, including the claimant’s statements.
Marvich v. Commissioner of Social Security · filed 2024-03-12(a)
The RFC must be based on all relevant evidence in the record, including medical evidence, medical reports and opinions, the claimant’s testimony, and statements the claimant made to medical providers.Read the full opinion on CourtListener →
Residual functional capacity measures the most a claimant can still do despite limitations.
Maldonado v. Commissioner of Social Security · filed 2024-03-13(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).Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can still do despite her limitations; paystubs showing time off do not require an absenteeism limit without evidence that impairments caused the absences or would cause continuing absences.
Rojas v. O'Malley · filed 2024-03-13(a)(1)
A claimant’s RFC is the measure of the most a claimant can do despite her limitations. 20 C.F.R. § 404.1545(a)(1); see Bowers v. Kijakazi, 40 F.4th 872, 875 (8th Cir. 2022) (“A claimant’s residual functional capacity is a measurement of their ability to do sustained physical or mental work, despite their health limitations.”). ... Plaintiff also has not shown that her impairments would cause her to be absent from work in the future or on a continuing basis. ... Therefore, the ALJ did not err by failing to include an absenteeism limitation based on Plaintiff’s paystubs.Read the full opinion on CourtListener →
A claimant’s residual functional capacity is the most she can do despite her functional limitations, and the assessment must be supported by the record.
HERNANDEZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2024-03-13(a)
A disability benefits claimant’s RFC is the most she can do when factoring in her functional limitations. 20 C.F.R. § 404.1545(a); SSR 96-8p. ... The Court finds that the ALJ properly examined the evidence in the record in reaching this decision and sufficiently articulated the bases for her conclusion.Read the full opinion on CourtListener →
Section 404.1545(a)(3) makes a claimant’s symptom testimony relevant to the residual functional capacity assessment.
Defferding v. Commissioner of Social Security · filed 2024-07-12(a)(3)
Had the ALJ properly evaluated Plaintiff’s testimony, the ALJ may have included additional limitations in the RFC, which may have resulted in a different disability determination. 20 C.F.R. §§ 404.1545(a)(3), 416.945(a)(3) (RFC dependent, in part, on Plaintiff’s subjective symptom testimony).Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an ALJ assessing residual functional capacity to consider a claimant’s impairments and related symptoms, including fatigue.
Morgan v. SSA · filed 2025-02-06(a)(1)
When determining a claimant’s RFC, an ALJ must consider their impairments as well as any related symptoms, such as fatigue. 20 C.F.R. §§ 404.1545(a)(1), 404.1529. ... Here, the Court finds that the ALJ’s determination of Morgan’s RFC was supported by substantial evidence because the ALJ relied on objective medical evidence and examinations, and adequately explained why Morgan’s subjective statements on her symptoms were not consistent with the record.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires the ALJ to develop the record when determining residual functional capacity; an RFC based on medical opinions that omit a critical body of later objective evidence lacks substantial evidence.
Stidham v. SSA · filed 2025-02-07(a)(3)
However, both the regulations and case law recognize the ALJ has a duty to develop the record. 20 C.F.R. §§ 404.1512(b), 416.912(b) (2016); 20 C.F.R. §§ 404.1545(a)(3), 416.945(a)(3) (2020); see also Lashley v. Sec’y of Health & Hum. Servs., 708 F.2d 1048, 1051- 52 (6th Cir. 1983).Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as the most a claimant can do on a regular and continuing basis despite limitations.
Breazeale v. Social Security Administration · filed 2025-02-12
The RFC is the most Claimant can do on a regular and continuing basis despite his limitations.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.
Camp v. Social Security Administration, Commissioner of · filed 2025-02-12(a)(1)
A claimant’s RFC is the most the claimant can do despite limitations. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... The ALJ considered these abnormalities when arriving at an adequate RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an ALJ to base residual functional capacity on all relevant medical and other evidence, without requiring it to match a medical opinion.
Blackstock v. Commissioner of Social Security · filed 2025-02-14(a)(3)
An ALJ bases their RFC determination on “all of the relevant medical and other evidence” in the case record. 20 C.F.R. § 404.1545(a)(3). ... An ALJ is not required to base an RFC on a medical opinion.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can do despite physical and mental limitations.
LAMAR v. COLVIN · filed 2025-02-18(a)
RFC measures the most a claimant can do despite any physical and mental limitations.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations.
(SS) Laflora v. Commissioner of Social Security · filed 2025-02-18(a)
As the ALJ’s RFC assessment is ultimately at issue here, the Court notes that a claimant’s RFC is “the most [a claimant] can still do despite [his] limitations.” 20 C.F.R. §§ 404.1545(a), 416.945(a); see also 20 C.F.R. Part 404, Subpart P, Appendix 2, § 200.00(c) (defining an RFC as the “maximum degree to which the individual retains the capacity for sustained performance of the physical-mental requirements of jobs”). ... Thus, based on the review of the record and ALJ opinion, the Court finds that the ALJ sufficiently supported the decision to not fully credit Plaintiff's subjective symptom testimony and the ALJ’s RFC was supported by substantial evidence.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.
RIVERS v. DUDEK · filed 2025-02-20(a)(1)
An RFC is the most a claimant can still do despite his or her limitations. 20 C.F.R. § 404.1545(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.
(SS) Carver v. Commissioner of Social Security · filed 2025-02-24(a)
A claimant’s RFC is “the most [a claimant] can still do despite [his] limitations.” 20 C.F.R. §§ 404.1545(a), 416.945(a); see also 20 C.F.R. Part 404, Subpart P, Appendix 2, § 200.00(c) (defining an RFC as the “maximum degree to which the individual retains the capacity for sustained performance of the physical-mental requirements of jobs”). ... While Plaintiff may wish for the ALJ to have provided more restrictions based on such evidence, this amounts, at most, to another rational interpretation of the evidence, which is not sufficient to conclude that the ALJ erred.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the maximum work a claimant can perform despite limitations; the assessment must have a medical basis.
Cliff v. O'Malley · filed 2025-02-25(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, however, the ALJ failed to build a logical bridge between the evidence and his conclusion that plaintiff can perform medium work with frequent overhead reaching.Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations from impairments; an assessment may account for severe and non-severe impairments together.
Dozier v. O'Malley · filed 2025-02-26(a)
Residual functional capacity is the most a claimant can still do despite the physical and mental limitations resulting from his impairments. ... The ALJ found the opinion of Dr. Huffman to be most persuasive but added additional restrictions regarding a 25-pound limitation on frequent lifting and carrying to account for Plaintiff’s non-severe impairments in combination with his severe one. (Tr. 21-24). Because the ALJ’s RFC determination was more limited than Dr. Huffman’s or that of any other provider of record, Plaintiff cannot show that any error occurred or that he was harmed.Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as what a claimant can still do despite limitations and requires consideration of all medically determinable impairments, including nonsevere ones.
Holder v. Dudek · filed 2025-02-26(a)
“[R]esidual functional capacity is the most [Plaintiff] can still do despite [her] limitations.” ... The RFC determination considers all medically determinable impairments, including those that are not severe. ... The Court therefore finds that the ALJ’s RFC determination is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider severe and non-severe impairments when evaluating a claimant’s ability to sustain work activities.
Carr v. Commissioner of Social Security · filed 2025-02-28
The RFC is a holistic assessment of the claimant's medical impairments, both severe and non-severe, that evaluates the claimant's ability to perform physical or mental work activities on a sustained basis, notwithstanding limitations for collective impairments.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity must carefully consider available evidence about a claimant’s symptoms, including flareups.
Rodriguez v. Kijakazi · filed 2025-03-28(a)(1)
In short, in determining the RFC, the ALJ’s analysis satisfies the ALJ’s obligation to provide careful consideration of the available evidence relating to Plaintiff’s asthma symptoms, including flareups.Read the full opinion on CourtListener →
An RFC assessment can account for fatigue by evaluating evidence of the claimant’s ability to work without repeatedly naming the symptom.
Durham v. Social Security, Commissioner of · filed 2025-08-28(a)
So Plaintiff is incorrect to say that the ALJ did not address how her fatigue and related symptoms impact her ability to do and sustain work-related functions because the ALJ addressed the evidence on her ability to work.Read the full opinion on CourtListener →
Section 404.1545 does not require additional RFC restrictions for fatigue allegations that the ALJ only partially accepts.
Quinto v. Commissioner of Social Security · filed 2025-09-11
Having only partially accepted Plaintiffs claimed levels of fatigue, the ALJ was under no obligation to assess any more restrictions than he did in Plaintiff's RFC.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider a claimant’s impairments and related symptoms when assessing residual functional capacity and to explain omitted limitations.
MARTIN v. O'MALLEY · filed 2025-09-22(a), (b)
An ALJ must determine a claimant’s exertional and non-exertional capacity only after considering all of a claimant’s impairments, as well as any related symptoms, including pain. See Hines, 453 F.3d at 562–63; 20 C.F.R. § 404.1545(b). ... Here, as the following discussion will show, the ALJ failed to adequately explain why he omitted limitations related to light exposure, time off-task, and absences from the RFC.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider all of a claimant’s impairments, including non-severe impairments, when assessing residual functional capacity.
Lopez Pagan v. Commissioner of Social Security · filed 2025-09-24(a)(2)
Given that the ALJ was required to consider all of Plaintiff’s impairments, severe and non-severe, in assessing her RFC, the ALJ’s failure to do so here constitutes error necessitating remand.Read the full opinion on CourtListener →
An RFC assessment must consider the effects of all impairments, but the ALJ need not name a PTSD diagnosis when the assessment addresses its symptoms and their effect on functioning.
Turek v. Commissioner of Social Security · filed 2025-09-26(e)
In sum, because the ALJ found other severe impairments at step two; referenced the causes and symptoms of Plaintiff’s PTSD throughout the decision; properly assessed Plaintiff’s mental impairment at step three; and discussed Plaintiff’s mental impairment when determining RFC at step four, the ALJ’s failure to explicitly refer to Plaintiff’s PTSD diagnosis is not an error warranting reversal.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to reflect what a claimant can do despite limitations; the ALJ must explain how fatigue is accommodated or why the claimant’s complaints are rejected.
Merriman · filed 2026-02-06(a)(1)
The RFC is the most someone “can do despite their mental and physical limitations.” 20 C.F.R. § 404.1545(a)(1) and § 416.945(a)(1); SSR 96-8p(5) (emphasis added). ... The ALJ never explains whether the assessed RFC limitations accommodate her fatigue or, in the alternative, articulate reasons why the ALJ rejected her complaints of fatigue. This warrants remand.Read the full opinion on CourtListener →
An RFC assessment must address whether frequent bowel movements and fatigue require restroom trips or extra breaks, or explain why those limits are unnecessary.
Stump · filed 2026-02-06
The court concludes that the AL] in this case erred because he did not explain why he found Brandon’s allegations of frequent and sometimes time-consuming bowel movements to be inconsistent with other evidence in the record, and because he did not either include a need for frequent trips to the restroom in the RFC or explain why such an accommodation was not necessary.Read the full opinion on CourtListener →
Section 404.1545 permits an RFC to address urinary frequency through nearby restroom access without specifying time off task when the record does not establish how often or how long the claimant needs restroom breaks.
HAAS · filed 2026-02-09(a)(1)
She did not testify as to how many times she went to the restroom during the workday, nor how long each visit lasted. ... In sum, the Court finds that the administrative record reflects that the ALJ considered all of Plaintiff’s functions in making the RFC determination, including her lavatory needs. ... The ALJ’s failure to account for time-off task therefore does not warrant remand.Read the full opinion on CourtListener →
An RFC assessment must address how the frequency and intensity of a claimant’s migraines affect attendance and the ability to stay on task when those limits may prevent work.
Wolfe · filed 2026-03-06(a)(3)
Therefore, the Commissioner’s final decision will be reversed and remanded for further consideration of the RFC with respect to the frequency and intensity of Wolfe’s migraines, in the context of the VE’s testimony about the attendance and on-task requirements of competitive employment.Read the full opinion on CourtListener →
Residual functional capacity assesses the work a claimant can perform despite limitations, and an assessment that depends on an unsupported rejection of pain-related limitations cannot stand.
Valiquette v. Astrue · filed 2007-08-03(a)
Furthermore, the ALJ’s conclusion that the plaintiff could perform sedentary work or work involving light exertion depended in substantial degree on his rejection of the plaintiffs description of the pain-related limitations on his ability to work. Accordingly, the conclusion that the plaintiff had a residual functional capacity to perform some work available in the national economy must also be set aside as unsupported.Read the full opinion on CourtListener →
Types of nonexertional limitations
Section 404.1545(d) treats epilepsy and environmental restrictions as nonexertional limitations.
Prill v. Schweiker · filed 1982-09-21(d)
This regulation (formerly 20 C.F.R. § 404.-1505(d)) was amended after the hearing before the ALJ. The amendment, designed to simplify and clarify, specifically indicates that epilepsy and environmental restrictions are considered impairments that do not limit physical exertion.Read the full opinion on CourtListener →
Section 404.1545(d) treats epilepsy as a nonexertional impairment when assessing residual functional capacity.
Bowker v. Heckler · filed 1984-11-01(d)
Epilepsy is clearly a nonexertional impairment. See 20 C.F.R. § 404.1545(d).Read the full opinion on CourtListener →
Section 404.1545(d) lists skin impairments and postural or manipulative limitations as nonexertional impairments.
Shelah COLE, Plaintiff-Appellant, v. SECRETARY OF HEALTH AND HUMAN SERVICES, Defendant-Appellee · filed 1987-06-01(d)
Channel v. Heckler, 747 F.2d 577 (10th Cir.1984), involved similar claims, and in addition, skin impairments and "postural/manipulative disability", which are specifically listed in the regulations as constituting nonexertional impairments. See id. at 578, 580; 20 C.F.R. Sec. 404.1545(d).Read the full opinion on CourtListener →
Section 404.1545(d) treats limits on bending, stooping, crouching, and kneeling as nonexertional postural limitations that must be considered in assessing work capacity.
STUNKARD v. SECRETARY OF HEALTH AND HUMAN SERVICES. Appeal of William STUNKARD · filed 1988-02-29(d)
As Stunkard suggests in his brief, these limitations should properly have been considered “postural” and, as such, should have been included in the AU’s findings as nonexertional limitations as defined in 20 C.F.R. § 404.1545(d).Read the full opinion on CourtListener →
Section 404.1545(d) treats loss of use of an arm as a nonexertional limitation.
Trimiar v. Louis W. Sullivan, M.D., Secretary of Health and Human Services · filed 1992-04-23(d)
The Secretary defines nonexertional impairments as “medically determinable impairments, such as skin impairments, epilepsy, and impairments of vision, hearing, or other senses, postural and manipulative limitations.” 20 C.F.R. § 404.1545(d) (1991). ... Appellant possesses nonexertional limitations arising from the loss of use of his right arm.Read the full opinion on CourtListener →
Section 404.1545 recognizes environmental restrictions as a type of non-exertional limitation.
Serra v. Sullivan · filed 1991-05-02
Plaintiff’s impairment does not stem from the type of environmental restriction described in 20 C.F.R. § 404.1545. Based on the factual record the AU expressly found, and this Court agrees, that plaintiff experiences “no non-exertional limitations.” (R., p. 12).Read the full opinion on CourtListener →
Section 404.1545(d) requires postural limitations to be considered as nonexertional limitations when assessing a claimant’s work capacity.
Pegg v. Sullivan · filed 1991-06-26(d)
Plaintiff’s limitations in standing, sitting and extending her head and neck, should properly have been considered “postural” under 20 C.F.R.. § 1545(d), and therefore, together with the pain, should have been included in the AU’s findings as nonexertional limitations.Read the full opinion on CourtListener →
Section 404.1545(c) and (d) treat pain and psychiatric problems as nonexertional impairments that cannot necessarily be measured through objective means.
Branson v. Callahan · filed 1998-04-21(c), (d)
Both pain and psychiatric problems, however, fall within the same category of “nonexertional impairments,” or impairments that cannot necessarily be measured or detected through objective means.Read the full opinion on CourtListener →
Section 404.1545(e) requires consideration of nonexertional restrictions when assessing a claimant’s ability to work.
Rivera v. Barnhart · filed 2005-07-28(e)
The ALJ also should have considered the nonexertional restrictions of Rivera’s impairment. See 20 C.F.R. §§ 404.1545(e), 416.945(e). Full consideration of these symptoms and complaints was necessary for the ALJ to determine the “total limiting effects” on Rivera’s ability to perform substantial gainful activity.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to account for supported nonexertional limitations or explain why they were discounted.
Dean v. Barnhart · filed 2006-02-06
In light of treating physician Dr. Grinman’s instructions to Plaintiff, the court concludes that the ALJ should have included the additional restrictions on exposure to heat, exhaustion, sleep deprivation, and dehydration into the RFC assessment, or at the very least, the ALJ should have articulated her reasons for discounting these additional restrictions.Read the full opinion on CourtListener →
Section 404.1545 does not require an RFC finding to separately list possible nonexertional limitations that the ALJ addressed elsewhere and found would not affect the claimant’s RFC.
Todd v. Colvin · filed 2017-12-22(a)
While the ALJ did not specifically address in Todd’s RFC her nonexertional limitations with regard to concentration, persistence, and pace or limitation to unskilled work, those possible limitations were addressed in the ALJ’s decision and would not tend to affect her RFC.Read the full opinion on CourtListener →
A residual functional capacity assessment must determine whether medically determinable headaches cause non-exertional limitations that should be included.
(SS) Basto v. Commissioner of Social Security · filed 2020-09-24(a)
The matter will be remanded to the agency to determine whether plaintiff’s headaches, which are a medically determinable impairment, result in non-exertional limitations which should be included in plaintiff’s residual functional capacity.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of exertional and nonexertional limitations in assessing residual functional capacity, including whether urinary frequency warrants an additional limitation.
Loyola v. Commissioner of Social Security · filed 2023-03-06
The regulations also provide that if a claimant suffers from a nonexertional impairment as well as an exertional impairment, both are considered in determining her residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945. ... Accordingly, this matter will be remanded to allow the ALJ to address whether additional limitations are warranted for Plaintiff’s alleged urinary frequency.Read the full opinion on CourtListener →
Combined impairments
Section 404.1545 requires an ALJ assessing residual functional capacity to consider the limiting effects of a claimant’s physical and mental impairments.
Davis · filed 2026-06-04(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).Read the full opinion on CourtListener →
Section 404.1545(e) requires an ALJ to consider the limiting effects of all impairments, severe and nonsevere, when assessing residual functional capacity; an adequate explanation need not discuss each impairment individually.
Golde · filed 2026-06-01(e)
An ALJ is required to consider the limiting effects of all a claimant’s impairments, severe and nonsevere, in the RFC. 20 C.F.R. § 404.1545(e). That said, an ALJ need only provide an adequate explanation to demonstrate all of a claimant’s impairments were considered, there is no requirement that impairments be individually discussed.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ to consider the effects of all medically determinable impairments, including severe and nonsevere impairments, when assessing residual functional capacity.
Harris · filed 2026-03-26(a)(2)
An ALJ must consider the effects of all the claimant’s medically determinable impairments—including those found severe and those found non–severe—when assessing the RFC. 20 C.F.R. § 404.1545(a)(2).Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments when assessing residual functional capacity, including non-severe impairments.
Brunner · filed 2026-04-02(a)(2)
In making this assessment, the ALJ must consider all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the RFC assessment to consider all known medically determinable impairments; a step-two omission is not harmless when the ALJ fails to consider the condition’s effect on RFC.
Marriott · filed 2026-03-25(a)(2)
However, as ALJ Bell did not consider plaintiff’s headache/migraine condition to be a medically determinable impairment, she did not go on to consider the impact of that condition on plaintiff’s RFC. [5] at 25, 27; see 20 C.F.R. §404.1545(a)(2) (“[w]e will consider all of your medically determinable impairments of which we are aware . . . when we assess your [RFC]”); Parker-Grose v. Astrue, 462 F. App’x 16, 18 (2d Cir. 2012).Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments when assessing residual functional capacity; an assessment supported by substantial evidence should stand.
Preston v. Comm'r of Soc. Sec. · filed 2023-06-20(a)(2)
So long as the ALJ considers all medically determinable impairments and supports her resulting opinion with substantial evidence, that decision should stand.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an RFC assessment to consider all medically determinable impairments, including those that are non-severe.
Ball v. Commissioner of Social Security · filed 2023-06-14(a)(2)
When determining the RFC, the ALJ must consider all medically determinable impairments, mental and physical, even those that are non-severe. ... In sum, contrary to Ball’s assertions, the ALJ adequately considered Ball’s symptom testimony pertaining to her IBS and urinary frequency, fairly reviewed the medical evidence (or the lack thereof) pertaining to these complaints, and adequately articulated his reasoning for discounting the severity of her allegations about her IBS symptoms and urinary frequency.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments when assessing residual functional capacity.
FLORES v. SAUL · filed 2019-12-16(a)(2)
The ALJ must consider all medically determinable impairments when assessing a claimant’s RFC. 20 C.F.R. § 404.1545(a)(2); see also Yurt v. Colvin, 758 F.3d 850, 857 (7th Cir. 2014) (“As a general rule, . . . the ALJ's RFC assessment must incorporate all of the claimant's limitations supported by the medical record.”).Read the full opinion on CourtListener →
Section 404.1545(e) requires the ALJ to consider the combined effects of severe and non-severe impairments when determining residual functional capacity.
Burton v. Berryhill · filed 2020-01-06(e)
The social security regulations require that the combined effect of all impairments – severe and non-severe – must be considered by the ALJ when determining the claimant’s RFC.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider severe and nonsevere physical and mental impairments together when assessing residual functional capacity.
Ortman v. Berryhill · filed 2019-12-13(a)(2)
When determining the RFC, the ALJ must consider all a claimant’s mental and physical impairments in combination, including those impairments that are severe and those that are not severe.Read the full opinion on CourtListener →
An RFC assessment may account for a nonsevere impairment without adding a limitation when the ALJ considers the relevant evidence and the medical record supports no further limitation.
HILL v. SAUL · filed 2019-12-18(a)(2)
The ALJ confronted the relevant evidence of record identified by John H., (Filing No. 10 at 13), when the ALJ explained her RFC finding, in part, by discussing the results of the two physical, consultative examinations that John H. had attended at the request of the SSA, (Filing No. 8-2 at 23-24). ... Accordingly, the Court does not find any error based on the ALJ’s consideration of John H.’s carpal tunnel syndrome.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of all impairments in assessing residual functional capacity, but an ALJ may give less weight to mental limitations unsupported by the record.
HICKS v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-11-15(a)(2)
The ALJ considers all impairments in this analysis, not just those deemed to be severe. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2); SSR 96-8p. ... Finally, the substantial evidence does not support Dr. D’Amato’s findings regarding Plaintiff’s mental limitations, and ALJ Kelly’s decision to consider them but give them less weight is proper.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ assessing residual functional capacity to consider limitations from all medically determinable impairments, including those that are not severe.
Primm v. Saul · filed 2019-11-21(a)(2)
The ALJ must consider all limitations imposed by medically determinable impairments, including by those that are not severe. 20 C.F.R. § 404.1545(a)(2). That happened here.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the agency to consider all known medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.
Inthavongsa v. Social Security Administration, Commissioner of · filed 2019-11-21(a)(2)
The regulations required the ALJ to consider all of Plaintiff’s MDIs, including CFS, in reaching a determination of his limitations and ability to work, and the court will not speculate as to how that evidence would have been treated had the ALJ actually considered it.Read the full opinion on CourtListener →
An RFC assessment must account for functional limitations from all impairments, including those that are not severe.
Padilla v. Berryhill · filed 2019-11-14(a)(1)-(2), (e)
An RFC must include an individual’s functional limitations or restrictions as a result of all of his impairments -- even those that are not severe (see 20 C.F.R. § 404.1545(a)(1)-(2), (e)) -- and must assess his “work-related abilities on a function-by-function basis.”Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an RFC assessment to consider medically determinable impairments, including nonsevere ones; limitations from conditions that are not medically determinable impairments need not be included.
Rahni v. Berryhill · filed 2019-11-14(a)(2)
But as discussed above, the ALJ properly confined her consideration to symptoms arising only from Plaintiff’s medically determinable impairments.Read the full opinion on CourtListener →
In determining residual functional capacity, an ALJ must consider severe and non-severe impairments in light of the medical evidence.
Conley v. Commissioner of Social Security · filed 2019-10-31(a)(2), (a)(4), (e)
In formulating a claimant’s RFC, the ALJ must consider all impairments and the extent to which the impairments are consistent with medical evidence. 20 C.F.R. § 404.1545(a)(2),(e). This includes both severe and non-severe impairments for determining if the claimant can “meet the physical, mental, sensory, and other requirements of work.” 20 C.F.R. § 404.1545(a)(4).Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an RFC assessment to consider severe and non-severe medically determinable impairments, but does not require it to include conditions that are not medically determinable.
SWITZER v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-10-25(a)(2)
Because the Court finds that substantial evidence supports the ALJ’s conclusion that Plaintiff’s fibromyalgia and depression were not medically determinable impairments, the ALJ consequently did not err by not including those conditions in the RFC analysis.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including non-severe impairments, together when assessing residual functional capacity.
Dias v. Berryhill · filed 2019-09-30(a)(2)
Indeed, under the regulations, an ALJ is required to asses all of a claimant’s medically determinable impairments – including those that are not severe – in combination when making the subsequent RFC determination.Read the full opinion on CourtListener →
An RFC assessment must consider limitations from all impairments, including those that are not severe.
Larsen v. Saul · filed 2019-10-07(a)(2)
However, an ALJ must consider “limitations and restrictions imposed by all of an individual’s impairments, even those that are not ‘severe.’”159 ... For the foregoing reasons, Ms. Larsen’s medically determinable limitations were adequately accounted for in the RFC and supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider severe and non-severe impairments and related symptoms that may cause physical or mental limitations.
Christian v. Social Security Administration, Commissioner · filed 2019-10-09(a)
More specifically, when assessing a claimant’s RFC, an ALJ must consider all severe and non-severe impairments and any related symptoms that may cause physical and mental limitations.Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC assessment to consider what a claimant can do despite the limitations caused by all of the claimant’s impairments.
Vancil v. Saul · filed 2019-09-30(a)
The RFC is defined as what the claimant can do despite his or her limitations, and includes an assessment of physical abilities and mental impairments. 20 C.F.R. § 404.1545(a). ... Then, the ALJ should prepare a new RFC determination considering all of the limitations caused by Vancil’s impairments.Read the full opinion on CourtListener →
Section 404.1545(e) requires the ALJ to consider all impairments, including nonsevere impairments, when determining residual functional capacity.
Whitlock v. Social Security Administration · filed 2019-10-04(e)
Once an ALJ finds that a claimant has a “severe” impairment at Step 2, the ALJ must then consider all impairments, including those that are not severe, in determining a claimant's RFC.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider how all of a claimant’s impairments affect the ability to perform work-related activities.
Kincaid v. Commisioner of SSA · filed 2019-09-24
A claimant’s residual functional capacity describes the most a claimant can do considering the effects of all his impairments on his ability to perform work-related activities. 20 C.F.R. § 404.1545. ... However, the Court finds that the ALJ’s RFC determination is not supported by substantial evidence because he failed to appropriately consider the effect of Plaintiff’s frequent urination on his ability to perform work-related activities.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, but does not require discussion of every piece of evidence when the decision is supported by substantial evidence.
Wolfenbarger v. Social Security Administration, Commissioner of · filed 2019-09-27(a)(2)
Additionally, an ALJ need not discuss every piece of evidence in the administrative record so long as he or she considers all of a claimant’s medically determinable impairments, and the opinion is supported by substantial evidence. See 20 C.F.R. § 404.1545(a)(2); see also Thacker v. Comm’r of Soc. Sec., 99 F. App’x 661, 665 (6th Cir. 2004).Read the full opinion on CourtListener →
An RFC assessment considers limitations from all medically determinable impairments, including those not found severe.
Whitworth v. Berryhill · filed 2019-09-18(a)(2)
Moreover, even if the ALJ erred in excluding Plaintiff's peripheral neuropathy and lumbar stenosis from the list of severe impairments, the Court finds such error was harmless because the ALJ clearly considered all of Plaintiffs limitations throughout her RFC analysis.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to consider all impairments when assessing residual functional capacity and to account for the work limitations caused by a severe impairment.
Rodriguez v. Kijakazi · filed 2019-09-11
In formulating the residual functional capacity, the ALJ must consider the claimant’s remaining ability to do physical and mental work activities on a sustained basis, considering all of the claimant’s impairments. 20 C.F.R. §§ 404.1545, 416.945. ... If an impairment is found severe, by definition it causes some limitations on the individual’s ability to perform work activities, and thus must be accounted for in the RFC.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity must consider evidence of functional limitations from a severe impairment and explain the limitations included in the assessment.
Alazzawi v. Commissioner of Social Security · filed 2019-09-04(a)(3)
However, by rejecting every limitation Dr. Wacker identified in his opinion, with no other medical opinion addressing the Crohn’s disease, it is unclear how the ALJ found there would be no limitations related to this impairment, given the substantial evidence that there would be limitations related to the Crohn’s disease, particularly bathroom use.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires the ALJ to consider all of a claimant’s impairments and symptoms when assessing residual functional capacity.
Curry v. Commissioner of Social Security · filed 2019-08-23(a)(2)
An ALJ must consider all of a claimant's impairments and symptoms and the extent to which they are consistent with the objective medical evidence. 20 C.F.R. § 404.1545(a)(2)(3).Read the full opinion on CourtListener →
An ALJ must consider all medically determinable impairments when assessing residual functional capacity, but need not discuss every piece of evidence if substantial evidence supports the assessment.
Chopka v. Social Security Administration · filed 2019-08-27(a)(2)
In fact, an ALJ generally need not discuss every piece of evidence in the administrative record so long as he or she considers all of a claimant’s medically determinable impairments and the opinion is supported by substantial evidence. ... Given that the ALJ relied heavily on these State consultant opinions, the Court finds that the ALJ did consider the April 2007 assessment.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider all of a claimant’s impairments and symptoms when assessing residual functional capacity.
Strickland v. Commissioner of Social Security Administration · filed 2019-08-30(a)(2)
An ALJ must consider all of a claimant’s impairments and symptoms and the extent to which they are consistent with the objective medical evidence. 20 C.F.R. § 404.1545(a)(2)(3). ... The ALJ also adequately considered all the relevant evidence about Plaintiff’s migraines. See tr. at 16-20. Therefore, the Court finds that the ALJ’s RFC determination, particularly with regard to her migraines, was supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a) requires consideration of all relevant impairments and related symptoms when assessing residual functional capacity, including the effects of obesity.
Page v. Saul · filed 2019-08-19(a)
In making this 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). ... Therefore, the Court finds that the ALJ did not properly consider Plaintiff’s obesity, and remand is warranted on this issue.Read the full opinion on CourtListener →
Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments when assessing residual functional capacity, but an impairment needs no RFC limitation when the record does not support a functional effect.
RICHMOND JR. v. SAUL · filed 2019-08-12(a)(2)
The ALJ must consider all medically determinable impairments when assessing a claimant’s RFC. ... Accordingly, the Court finds that the ALJ’s did not need to include RFC limitations regarding headaches and his RFC determination is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545 requires consideration of a claimant’s impairments in combination when assessing residual functional capacity.
Johness F. SWINDLE, Plaintiff-Appellant, v. Louis W. SULLIVAN, as Secretary, Department of Health and Human Services, De · filed 1990-10-10
In evaluating a claimant’s residual function capacity, the AU must consider a claimant’s impairments in combination. 20 C.F.R. § 404.1545 (1989); Reeves v. Heckler, 734 F.2d 519, 525 (11th Cir.1984). Because the AU improperly discounted Ms. Swindle’s subjective complaints of pain and dizziness, he did not give adequate consideration to the effect the combination of her exertional and non-exertional impairments has on her ability to work. Therefore, this case must be remanded to the AU for reconsideration of Ms. Swindle’s residual functional capacity.Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can still do despite physical or mental limitations, considering all impairments.
Taylor v. Bowen · filed 1988-07-13(a)
A plaintiffs residual functional capacity is based upon what the party can still do despite her physical or mental limitations. 20 C.F.R. § 404.1545(a) (1986). If there is more than one impairment, all of the impairments will be considered in determining the plaintiffs residual functional capacity.Read the full opinion on CourtListener →
Section 404.1545(a) requires the Secretary to consider all of a claimant’s impairments when determining residual functional capacity.
Rodriguez v. Schweiker · filed 1981-10-07(a)
Under 20 C.F.R. § 404.1545(a), where a claimant suffers from more than one impairment, the Secretary is bound to consider all impairments in determining the claimant’s residual functional capacity.Read the full opinion on CourtListener →
Section 404.1545(a) requires the agency to consider all known impairments together when determining residual functional capacity.
Maisch v. Heckler · filed 1985-03-22(a)
Similarly, 20 C.F.R. § 404.1545(a) provides that the Secretary should consider all known impairments together in order to determine residual functional capacity.Read the full opinion on CourtListener →
Notes 301–450 of 6,798, oldest cases first.
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