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.
Medical support for RFC findings
Section 404.1545(a)(1) permits an ALJ to omit an alleged limitation from the residual functional capacity finding when substantial evidence supports that finding.
Becky Loop v. Colvin · filed 2016-06-10(a)(1)
The ALJ did not err by failing to include an impaired ability to talk and hear on the telephone in her finding regarding Loop’s residual functional capacity. Substantial evidence, including Loop’s own testimony about the effectiveness of her hearing aids and her reason for leaving the call center job, supported the ALJ’s finding.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to determine a claimant’s residual functional capacity from all relevant evidence, including medical records and the claimant’s description of limitations.
Willie Boyd, Jr. v. Colvin · filed 2016-08-05(a)(1)
“[A] claimant’s RFC [is] based on all relevant evidence, including the medical records, observations of treating physicians and others, and an individual’s own description of his limitations.” Moore, 572 F.3d at 523 (quotation and citation omitted). Accordingly, it is the responsibility of the ALJ, not a physician, to determine a claimant’s RFC.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to account for mental limitations in residual functional capacity; excluding jobs with strict production quotas or a fast pace does not, without support, account for a moderate limitation in concentration, persistence, and pace.
O'Connor-Spinner v. Colvin · filed 2016-08-09(c)
Yet the Commissioner has not cited, nor have we found, any authority supporting the ALJ’s speculation that eliminating jobs with strict production quotas or a fast pace may serve as a proxy for including, as part of the claimant’s mental residual functional capacity, a moderate limitation on concentration, persistence, and pace.Read the full opinion on CourtListener →
Residual functional capacity must be assessed using all relevant evidence in the record.
Salaiz v. Colvin · filed 2016-08-11(a)(1)
The RFC must be assessed based on all the relevant evidence in the record.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do in spite of her limitations.
Reece v. Colvin · filed 2016-08-24(a)(1)
An RFC is the most a claimant can do in spite of her limitations.Read the full opinion on CourtListener →
Section 404.1545(a) requires the ALJ to determine residual functional capacity from all relevant medical and other evidence.
Woodson v. Commissioner Social Security · filed 2016-09-28(a)
The ALJ is responsible for making the RFC finding based on all relevant medical and other evidence. See 20 C.F.R. §§ 404.1545(a), 404.1546(c).Read the full opinion on CourtListener →
Section 404.1545(a)(3) directs an ALJ to consider all relevant medical and other evidence when assessing residual functional capacity.
Johnson v. Colvin · filed 2016-09-29(a)(3)
In concluding that Johnson could “perform light work,” S.A. 21, the ALJ relied on a variety of evidence. See 20 C.F.R. § 404.1545(a)(3) (explaining that an ALJ looks to “all of the relevant medical and other evidence” including relevant medical reports, consultative examinations, medical history, and statements from medical sources, family, friends, or other persons when assessing an applicant’s residual functional capacity).Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ to base a residual functional capacity assessment on all relevant evidence in the case record.
Igo v. Colvin · filed 2016-10-13(a)
The ALJ’s RFC assessment must be based on “all the relevant evidence in [the] case record.” 20 C.F.R. § 404.1545(a). ... Because the ALJ expressly considered all of the limitations that Igo cites, we conclude that the ALJ did not err.Read the full opinion on CourtListener →
Residual functional capacity measures the most a claimant can do despite his impairments.
Valencia v. Commissioner of Social Security · filed 2016-10-19(a)(1)
RFC is the most, not the least, a claimant can do despite his impairments.Read the full opinion on CourtListener →
Section 404.1545 treats residual functional capacity as the most a claimant can still do on a regular and continuing basis despite impairments.
Compton v. Colvin · filed 2016-10-31
Residual functional capacity is the individual’s maximum remaining ability to do sustained work activities in an ordinary work setting on a regular and continuing basis.Read the full opinion on CourtListener →
Section 404.1545(a) does not require an RFC finding to be supported by a specific medical opinion.
Hensley v. Colvin · filed 2016-07-18(a)
However, there is no requirement that an RFC finding be supported by a specific medical opinion.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a person can still do despite limitations, making evidence of functional limitations relevant to the assessment.
Scott v. Berryhill · filed 2017-09-14(a)(1)
In determining whether an individual is disabled under the Act, probative evidence is that which demonstrates “the most [a person] can still do despite [his or her] limitations.” See 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1) (describing criteria for formulating RFC); Kruse v. Astrue, 436 Fed.Appx. 879, 885 (10th Cir. 2011). ... Plaintiff fails to demonstrate how observations of a guarded Lachman’s and positive McMurray’s signs contradict the RFC or medical opinions regarding Plaintiffs ability to work, where the knee pain improved since the examination and there was no significant alteration in treatment or pain medications.Read the full opinion on CourtListener →
Section 404.1545 does not require an RFC to include limitations that the record does not support.
Wessling v. Berryhill · filed 2018-08-15(a)(1)
Further, the record does not support additional or more severe mental limitations. Accordingly, the Court finds the ALJ did not err in failing to include additional or more severe mental limitations.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC assessment to rest on relevant evidence; when the ALJ rejects medical opinions, the ALJ must identify a medical basis for the limitations chosen.
Myles v. Berryhill · filed 2018-08-21(a)(1)
After largely discrediting the opinions of Dr. Elmes and the state agency physicians, the ALJ was then required to call a medical expert or, alternatively, explain what other medical basis he relied on in making Claimant’s RFC determination.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity may not replace limitations in a medical opinion with unsupported findings of greater functional capacity.
Richard Roger Wilkins, Jr. v. Nancy A. Berryhill, Acting Commissioner, Social Security Administration · filed 2018-10-15(a)
But an ALJ is not entitled to do what the ALJ did here, which was to replace three of Dr. Lipski’s limitations not with limitations from a contradictory medical opinion, but with her own view that Wilkins had an unlimited capacity for kneeling, stooping, and stair-and-ramp climbing.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an ALJ to assess residual functional capacity from all relevant evidence without adopting the precise limitations proposed by a single medical source.
McCoy v. Comm'r of Soc. Sec. · filed 2018-11-29(a)(3)
However, an ALJ is not required to adopt precise limitations offered by a single medical source in assessing a claimant's RFC. 20 C.F.R. § 404.1545(a)(3). Rather, the ALJ is responsible for assessing a claimant's RFC based on all of the relevant medical and other evidence.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite her limitations and must have substantial evidentiary support, including some medical evidence.
Booth v. Berryhill · filed 2019-01-17(a)(1)
A Residual functional capacity (RFC) is the most a claimant can still do despite her limitations. 20 C.F.R. § 404.1545(a)(1). It must be supported by substantial evidence, and include at least some medical evidence.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite mental and physical limitations, and its assessment must have supporting medical evidence.
Colwell v. Berryhill · filed 2019-01-17(a)(1)
At step four, the Commissioner must determine the claimant’s RFC, which is the most the claimant can do despite the claimant’s mental and physical limitations. Brown v. Barnhart, 390 F.3d 535, 538-39 (8th Cir. 2004) (citing 20 C.F.R. § 404.1545(a)(1)). ... The RFC is a medical question, and Colwell’s argument does not refute that “at least some” medical evidence supports the ALJ’s RFC determination.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to give a medical opinion great weight without including every finding in the residual functional capacity assessment when substantial evidence supports the assessment.
Orozco v. Berryhill · filed 2018-12-13
Substantial evidence supports the ALJ’s decision to afford great weight to Dr. Power’s medical opinions without including every such opinion in the RFC formulation.Read the full opinion on CourtListener →
Residual functional capacity may be determined from the medical and testimonial evidence without adopting a physician’s limitations that are unsupported by or inconsistent with the record.
Jones v. Berryhill · filed 2019-08-02
While Plaintiff argues that the ALJ substituted her own medical judgment for that of Dr. Herr's, as has been discussed in the statement of error above, the ALJ properly evaluated the evidence of record and appropriately discounted Dr. Herr's opined limitations that were inconsistent with, or unsupported by, the record. ... The ALJ properly evaluated the evidence in reaching this RFC determination, and the Regulations do not require more.Read the full opinion on CourtListener →
An RFC assessment must reflect what a claimant can still do despite limitations and have substantial evidentiary support for its functional findings.
(SS) Hernandez v. Commissioner of Social Security · filed 2019-08-02(a)
A claimant’s residual functional capacity is “the most [a claimant] can still do despite [her] 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”). ... Without physicians’ opinions to support the ALJ’s conclusions, the Court is unable to find substantial evidence supports the RFC determination.Read the full opinion on CourtListener →
In assessing RFC at step four, a court may consider whether medical appointments can be scheduled around work.
Doxtator v. Social Security Administration, Commissioner of · filed 2020-02-18
Further, many of the appointments appear to be of the type which could be scheduled to accommodate work; for instance, diabetes followups, medication refills or reviews, and post-op checks. This is a factor a court may consider in deciding whether a plaintiff has carried the burden of proving his or her RFC at step four.Read the full opinion on CourtListener →
A residual functional capacity finding need not be supported by a specific medical opinion.
Hoskin v. Saul · filed 2020-02-21(a)(1)
However, there is no requirement that an RFC finding be supported by a specific medical opinion.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires development of a claimant’s complete medical history, including a consultative examination when necessary; an examination is unnecessary when the claimant shows no gap in the medical evidence warranting one.
MacFarlane v. Commissioner of Social Security · filed 2020-03-25(a)(3)
Plaintiff has not demonstrated that there is a gap in the medical evidence of record that warrants a consultative examination.Read the full opinion on CourtListener →
An ALJ may assess residual functional capacity without a medical opinion when the record contains sufficient evidence to do so.
Taylor v. Commissioner of Social Security · filed 2020-03-26(a)(3)
Moreover, contrary to Taylor’s argument, the ALJ did not err in assessing the RFC without a medical opinion.Read the full opinion on CourtListener →
An ALJ must develop enough evidence to support a reasonable residual functional capacity assessment and explain how it was reached.
Solis v. Saul · filed 2020-03-27
It was the ALJ’s duty to: (1) develop the record to a sufficient degree to enable her to construct a reasonable RFC based on objective evidence (including, if necessary, calling or recalling a medical advisor and/or obtaining clarification of the record); and (2) articulate clearly how and why that finding was reached.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ assessing residual functional capacity to consider all relevant medical and other evidence, including relevant evidence from an acupuncturist.
Falciano v. Berryhill · filed 2020-03-27(a)(3)
The opinion of Mr. Kim—the acupuncturist—similarly constitutes “relevant” record evidence.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider all relevant medical and other evidence when assessing residual functional capacity.
Cunnington v. Commissioner of Social Security · filed 2020-03-28(a)(1), (a)(3)
The ALJ must also consider all relevant medical and other evidence when making an RFC determination. See 20 C.F.R. §§ 404.1545(a)(1), (3).Read the full opinion on CourtListener →
Section 404.1545 assesses what a claimant can still do despite limitations; sedentary work with a sit-stand option can account for supported functional restrictions.
Svendsen v. Saul · filed 2020-03-30(a)(1)
By limiting Plaintiff to sedentary work with a sit-stand option, the ALJ recognized and incorporated the serious functional limitations present in Dr. Cowl’s opinion into Plaintiff’s residual functional capacity, crediting his opinion over the less restrictive opinions of the state agency medical consultants.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite limitations caused by impairments, assessed in light of the relevant evidence.
Beamer v. Berryhill · filed 2020-03-30(a)
RFC is defined as the most a claimant can still do despite the physical and mental limitations resulting from her impairments. See 20 C.F.R. §§ 404.1545(a), 416.945(a). ... The ALJ’s RFC formulation reflects careful consideration of all evidence related to Plaintiff’s credible limitations, and the Court finds no error in its construction.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can do despite limitations.
Case v. Berryhill · filed 2020-03-30(a)(1)
RFC is defined as “the most a claimant can do despite her limitations.” Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009) (citing 20 C.F.R. § 404.1545(a)(1)). ... The Court finds that substantial evidence supports this conclusion, including the medical records discussed above as well as Plaintiff's and the VE’s testimony at the hearing.Read the full opinion on CourtListener →
A residual functional capacity finding must account for impairment-related limitations and have specific support in the medical record.
Iorio v. Commissioner of Social Security · filed 2020-03-30(a)(1)
Because the ALJ’s RFC determination was largely unsupported by specific evidence in the record, the Court finds that the ALJ improperly substituted his own opinion for the findings of Plaintiff’s medical sources.Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as the most a claimant can do despite her limitations.
Argenti v. Commissioner of Social Security · filed 2020-03-30
RFC is the most an individual can do despite her limitations. 20 C.F.R. §§ 404.1545, 416.945. ... Accordingly, Plaintiff’s objection that the ALJ’s RFC assessment was not supported by substantial evidence is OVERRULED.Read the full opinion on CourtListener →
Residual functional capacity is based on all relevant record evidence; an ALJ need not explicitly address claimed panic attacks when the assessment is supported by that evidence.
TIRADO v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-03-30(a)(1)
The RFC is a determination of “the most [a claimant] can still do despite [] limitations” “based on all the relevant evidence in [the] case record.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1); SSR 96-8p, at *2. ... Accordingly, it was not error for the ALJ to not explicitly address evidence regarding Plaintiff’s claimed panic attacks.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite mental and physical limitations.
Rathke v. Saul · filed 2020-03-30(a)(1)
At step four, the Commissioner must determine the claimant’s RFC, which is the most the claimant can do despite the claimant’s mental and physical limitations. Brown v. Barnhart, 390 F.3d 535, 538-39 (8th Cir. 2004) (citing 20 C.F.R. § 404.1545(a)(1)).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite his limitations.
Phillips v. Social Security Administration, Commissioner of · filed 2020-03-30(a)(1)
An RFC is the most a claimant can do despite his limitations. 20 C.F.R. §§ 404.1545(a)(1) and 416.945(a)(1).Read the full opinion on CourtListener →
An RFC assessment includes only limitations the ALJ finds credible and supported by substantial evidence.
Cuevas v. Commissioner of Social Security · filed 2020-03-31(a)(1)
In making this finding, the ALJ need only include credible limitations supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires the ALJ to consider all relevant medical and other evidence when assessing residual functional capacity; state agency medical opinions and the ALJ’s review of the medical evidence can provide adequate support.
Herring v. Commissioner of Social Security · filed 2020-03-31(a)(3)
It is necessary for an ALJ to independently review the medical evidence in crafting an RFC. Here, adequate medical evidence supports the RFC because the ALJ relied on the opinions of two state agency medical consultants and his own independent review of the medical evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(3) makes the claimant responsible for providing evidence about residual functional capacity and requires the Commissioner to develop the claimant’s complete medical history.
Scott v. Saul · filed 2020-03-31(a)(3)
Ultimately, the claimant is responsible for providing evidence relating to her RFC and the Commissioner is responsible for developing the claimant’s “complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [the claimant’s] own medical sources.” 20 C.F.R. §§ 404.1545(a)(3), 416.945(a)(3) (emphasis in original).Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an ALJ to consider a claimant’s impairments and related symptoms when determining residual functional capacity.
Perry v. Commissioner of Social Security · filed 2020-03-31(a)(1)
To determine the claimant’s RFC, the ALJ must consider the claimant’s “impairment(s), and any related symptoms . . . [which] may cause physical and mental limitations that affect what [the claimant] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1). ... Accordingly, given that none of the consultative opinions are sufficient to support the ALJ’s RFC determination, which is contradicted by the treating source opinion, the Court finds that remand is necessary to allow the ALJ to fully develop the record and make a proper determination as to Plaintiff’s RFC based on opinions from appropriate treating, medical, and/or other sources.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires the ALJ to consider impairments and related symptoms that may limit what a claimant can do at work when determining residual functional capacity.
Avrutskaya v. Commissioner of Social Security · filed 2020-03-31(a)(1)
To determine the claimant’s RFC, the ALJ must consider the claimant’s “impairment(s), and any related symptoms . . . [which] may cause physical and mental limitations that affect what [the claimant] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ to assess residual functional capacity using all relevant evidence, including the effects of the claimant’s impairments.
King, Jr. v. Berryhill · filed 2020-03-31(a)
The ALJ must assess a plaintiff’s residual functional capacity “based on all the relevant evidence in the case record.” Colegrove v. Comm’r of Soc. Sec., 399 F. Supp. 2d 185, 192 (W.D.N.Y. 2005) (citing 20 C.F.R. §§ 404.1545(a), 416.945(a)(1)). ... The ALJ discussed both conditions at length in her decision, and remand is not appropriate on this basis.Read the full opinion on CourtListener →
An ALJ must consider impairments and related symptoms when determining residual functional capacity and have sufficient medical evidence to support that determination.
Lobaido v. Commissioner of Social Security · filed 2020-03-31(a)(1)
Here, there were obvious gaps in Plaintiff’s medical record that the ALJ failed to attempt to fill. Thus, the ALJ erred by not adequately developing the record before making his RFC determination.Read the full opinion on CourtListener →
Section 404.1545(a) calls for consideration of all relevant evidence when assessing residual functional capacity, including a claimant’s reported limitations and daily activities.
DEASE v. BERRYHILL · filed 2020-03-31(a)(1), (a)(3)
When determining an individual’s RFC, an ALJ assesses all relevant evidence from the record, including statements from medical sources and a claimant’s own description of his limitations. See 20 C.F.R. § 404.1545(a)(1), (3). Thus, it is appropriate for an ALJ to consider the number and type of activities in which a claimant engages when assessing his RFC.Read the full opinion on CourtListener →
Section 404.1545 defines residual functional capacity as the most a claimant can do despite limitations.
WHITEFIELD v. BERRYHILL · filed 2020-03-31(a)
A claimant’s RFC is the most that he or she can do despite his or her limitations. See 20 C.F.R. §§ 404.1545(a), 416.945(a). ... Thus, after careful review, the Court finds that the ALJ did not fail to include in the RFC adequate limitations related to Plaintiff’s impairments.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite his limitations.
Horne v. Social Security Administration, Commissioner of (PLR2) · filed 2020-03-31(a)(1)
An RFC is the most a claimant can do despite his limitations.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to assess each work-related mental activity or rely on a medical consultant who has done so.
Gipson v. Berryhill · filed 2020-03-27(c)
Here, the ALJ did not conduct a function-by-function analysis of each work-related mental activity, nor did she rely on a medical consultant that did.Read the full opinion on CourtListener →
Residual functional capacity describes the most a claimant can still do despite limitations, and the ALJ may translate medical opinions into functional work limits.
Slape v. Commissioner of Social Security · filed 2020-03-27(a)(1)
However, as the Magistrate noted, the ALJ had to translate Dr. Gilcrease’s opinions in order to make findings for the “residual functional analysis.”Read the full opinion on CourtListener →
Section 404.1545 does not require a specific medical opinion to support an RFC finding when other record evidence provides a sufficient basis for it.
Moeding v. Saul · filed 2020-03-31(a)(3)
An ALJ is permitted to issue a decision without obtaining additional medical evidence, so long as other evidence in the record provides a sufficient basis for that decision.Read the full opinion on CourtListener →
An RFC assessment must account for conflicting medical evidence; an assessment that selectively relies on favorable findings may lack substantial evidence.
Sacks v. Commissioner of Social Security · filed 2020-04-03(a)
Given the contradicting medical evidence as stated above, the Court finds that the ALJ’s RFC analysis is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an ALJ to assess what a claimant can still do despite limitations using evidence that supports the claimant’s functional capacity.
Santiago v. Berryhill · filed 2020-04-20(a)(1)
Because there is no medical source opinion or functional assessment supporting the ALJ’s finding that Ms. Santiago can perform light work with limitations, the Court concludes that the RFC determination is without substantial support in the record and a remand for further administrative proceedings is appropriate.Read the full opinion on CourtListener →
Residual functional capacity may be assessed from the medical record even when no treating physician provides a functional assessment.
Joanie Graves v. Berryhill · filed 2020-04-21(a)(1)
As noted above, an RFC is what a claimant can still do despite existing exertional and nonexertional limitations. See 20 C.F.R. §§ 404.1545(a)(1). ... As noted, none of Plaintiff’s treating physicians provided any functional assessments of her limitations and Plaintiff points to no medical opinions or assessments that the ALJ disregarded. ... The Court finds no error by the ALJ in considering the medical record in assessing Plaintiff’s RFC.Read the full opinion on CourtListener →
Section 404.1545(a) does not always require an ALJ to obtain a medical opinion to determine residual functional capacity.
Ziegler, Amanda v. Berryhill, Nancy · filed 2020-05-08(a)
At the outset, to the extent that plaintiff suggests that ALJ is always required to solicit a medical opinion in order to translate medical evidence into an RFC finding, she is simply mistaken.Read the full opinion on CourtListener →
Section 404.1545(a)(3) permits an ALJ to assess residual functional capacity from all relevant evidence without a physician's opinion when the evidence requires no medical expertise to interpret.
Rosario v. Saul · filed 2020-05-13(a)(3)
An ALJ determines a claimant's RFC based on all relevant evidence, including medical history, medical signs, laboratory findings, the effects of treatment, daily activities, lay evidence, and medical source statements. See 20 C.F.R. § 404.1545(a)(3). ... Second, contrary to Plaintiff's contention, the ALJ was capable of making sense of the evidence without a physician's opinion.Read the full opinion on CourtListener →
A highly specific residual functional capacity finding requires medical opinion evidence when the record does not establish the claimant’s functional limits.
Balistrieri v. Commissioner of Social Security · filed 2020-06-02
Failure to provide medical opinion evidence in support of a highly specific RFC statement requires remand.Read the full opinion on CourtListener →
Section 404.1545(b) does not require a physician’s opinion that matches the ALJ’s physical residual functional capacity finding.
Sisk v. Social Security Administration · filed 2020-06-03(b)
The Sixth Circuit has “rejected the argument that a residual functional capacity determination cannot be supported by substantial evidence unless a physician offers an opinion consistent with that of the ALJ.” ... The ALJ properly evaluated the evidence in reaching this RFC determination, and the Regulations do not require more.Read the full opinion on CourtListener →
An RFC assessment must have evidentiary support that allows a court to understand how the ALJ determined the claimant’s functional limitations.
STOUP v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-06-05(a)
I find there is ambiguity in the record as to how the ALJ arrived at Plaintiff’s functional limitations in his RFC determination. As a result, I am unable to make a proper meaningful review.Read the full opinion on CourtListener →
An ALJ assessing mental residual functional capacity must obtain medical opinion evidence about functional limitations when the record lacks it.
Cooks-Sanders v. Commissioner of Social Security · filed 2020-06-08
As there were no medical opinions assessing Plaintiffs mental limitations, the ALJ should have taken steps to obtain such evidence.Read the full opinion on CourtListener →
An ALJ may assess physical residual functional capacity without a medical opinion directly evaluating work-related functions when the record provides sufficient evidence to make the assessment.
McCoy v. Commissioner of Social Security · filed 2020-06-18(a)
Nothing in the record suggests that this physical impairment limited her ability to engage in work-related activities. Under such circumstances, I conclude that the ALJ was permitted to formulate an RFC without a medical opinion that directly assessed McCoy’s physical ability to complete work-related functions.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess residual functional capacity from the whole record without a medical opinion supporting each specific limitation.
Hallman v. Commissioner of Social Security · filed 2020-06-16(a)(3)
Contrary to plaintiff’s argument, a medical opinion is not required to make a specific RFC finding.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess residual functional capacity from the record as a whole without a medical opinion when the evidence is sufficient.
Price v. Commissioner of Social Security · filed 2020-07-27(a)(3)
Overall, the ALJ did not commit legal error in formulating an RFC absent a medical opinion. The ALJ properly considered all of the evidence in the record as a whole and formulated an RFC based on that evidence.Read the full opinion on CourtListener →
An RFC assessment may rely on relevant medical and other evidence without a clinical or consultative opinion when the evidence does not require professional interpretation.
Hamilton v. Commissioner of Social Security · filed 2020-07-27(a)(3)
The above clinical notes, and others that the Commissioner has cited, show a consistent pattern: Plaintiff certainly has the severe impairments that the ALJ noted, but the impairments do not rise to a level where a clinical or consultative opinion would be necessary to interpret plaintiff’s functioning.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity cannot infer a claimant’s work limitations from treatment notes after rejecting all medical opinion evidence.
Pierce v. Commissioner of Social Security · filed 2020-07-29(a)(1)
While it is true that the ALJ must consider the record evidence as a whole in determining RFC, that does not permit an ALJ to make medical determinations from treatment notes concerning the effect of a claimant’s limitations on his or her ability to work, which is what the ALJ did here after rejecting all of the opinion evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(3) allows an ALJ to assess residual functional capacity from the whole record without an updated medical opinion when the evidence is sufficient.
Abate v. Commissioner of Social Security · filed 2020-08-11(a)(3)
Plaintiff’s argument, the ALJ’s RFC determination was the product of legal error because it was not based on an updated medical opinion, is without merit.Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC assessment based on all relevant medical and other evidence of what a claimant can still do despite limitations.
Palmer v. Saul · filed 2020-08-14(a)(1), (a)(3)
The Court finds that there is substantial evidence in the record to support this RFC, including the ability to sit for up to six hours, with a sit/stand option provided.Read the full opinion on CourtListener →
An ALJ assessing residual functional capacity must carefully consider medical opinions that support disability, especially before rejecting them in favor of a lay assessment of other evidence.
Sceranka v. Saul · filed 2020-08-19
Those cases which emphasize the importance of medical opinion support for an RFC assessment typically arise in the factual setting where a well-supported medical source has opined regarding limitations which would support a disability claim, but an ALJ has rejected the medical opinion which supported a disability determination based upon a lay assessment of other evidence. In this setting, these cases simply restate the commonplace idea that medical opinions are entitled to careful consideration when making a disability determination, particularly when those opinions support a finding of disability.Read the full opinion on CourtListener →
Section 404.1545(a) allows the ALJ to assess residual functional capacity from the record without a medical opinion supporting each limitation.
MacDonald v. Social Security Administration, Commissioner of · filed 2020-08-27(a)
There is no need in this case, or in any other, for the Commissioner to base the limitations in his RFC assessment upon specific statements in medical evidence or opinions in the record.Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC assessment supported by substantial evidence; an ALJ generally cannot translate significant raw medical findings into functional limitations through lay judgment alone.
Brown v. Commissioner of Social Security · filed 2020-08-27(a)
Therefore, the physical limitations set forth within ALJ's residual functional capacity which are clearly based on a lay person's intuition, as opposed to a medical opinion, are not supported by substantial evidence in the record.Read the full opinion on CourtListener →
An RFC assessment may rely on an earlier medical opinion when later evidence does not undermine it.
Schreiner v. Commissioner of Social Security · filed 2020-09-03(a)
Here, I disagree that Schwab’s consultative medical opinion was rendered stale by Schreiner’s subsequent diagnosis of MALT lymphoma, and I find that the RFC is otherwise supported by substantial evidence.Read the full opinion on CourtListener →
An ALJ must connect the evidence to RFC findings about how long a claimant can stand and walk.
Hentz v. Saul · filed 2020-09-01(a)(1)
While the ALJ need not discuss every piece of evidence, the ALJ nonetheless must build a logical bridge from the evidence to the RFC findings that Plaintiff can stand and walk up to six hours.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires the ALJ to develop the claimant’s complete medical history before assessing residual functional capacity.
Tucker v. Commissioner of Social Security · filed 2020-09-24(a)(3)
Before assessing a claimant’s RFC, the Administrative Law Judge is responsible for developing the claimant’s “complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [her] own medical sources.”Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess residual functional capacity without a medical expert’s assessment when the evidence shows relatively mild impairments with no significant functional restrictions apparent to a layperson.
Santiago-Borrero v. Commissioner of Social Security · filed 2020-09-28(a)
The evidence suggests relatively mild physical impairments posing no significant functional restrictions to a layperson’s eyes. ... Therefore, the ALJ did not err in finding that Plaintiff had the RFC to complete light work without a medical expert’s RFC assessment.Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations; an ALJ’s assessment must be supported by substantial evidence.
Hastings v. Saul · filed 2020-09-29(a)(1)
After careful review of the record, although it is a close question, the Court finds substantial evidence to support the ALJ’s RFC determination.Read the full opinion on CourtListener →
Section 404.1545 does not require a leg-elevation restriction in the residual functional capacity finding when the evidence does not show that the claimant must elevate his legs during the workday.
Jozefyk v. Saul · filed 2020-10-02(a)
Nor does the cited evidence suggest that he would be required to elevate his legs during a workday. ... Thus, the ALJ did not err in his RFC finding by failing to consider Jozefyk’s leg edema or these two recommendations that he elevate his legs.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires development of the claimant’s medical history, including a consultative examination when necessary; an examination is unnecessary when the existing medical evidence permits an RFC determination.
Atchley v. Saul · filed 2020-09-30(a)(3)
A consultative examination is not warranted when, as is the case here, the ALJ can properly determine the RFC from the medical evidence provided.Read the full opinion on CourtListener →
An ALJ may assess residual functional capacity from the whole record without a medical opinion that states the precise limitations found.
Weiss v. Commissioner of Social Security · filed 2020-10-19(a)(3)
In general, an ALJ’s RFC determination is not fatally flawed merely because it was formulated absent a medical opinion.Read the full opinion on CourtListener →
An RFC assessment must rest on record evidence, and an unsupported sit/stand limitation fashioned from vocational expert testimony requires remand.
Kubiszewski v. Commissioner of Social Security · filed 2020-11-10(a)(3)
The RFC must be based on the evidence in the record and the testimony of the claimant or her friends and family. 20 C.F.R. § 404.1545(a)(3). The ALJ’s failure to support the sit/stand option with evidence in the record, as well as the apparent crafting of the RFC based on the VE’s testimony requires remand.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess residual functional capacity from the record as a whole without a specific medical opinion when the evidence is sufficient.
Eakman v. Commissioner of Social Security · filed 2020-11-19(a)(3)
An ALJ’s RFC determination is not fatally flawed merely because it was formulated absent a medical opinion.Read the full opinion on CourtListener →
An ALJ may determine residual functional capacity without basing the finding on a medical opinion.
Kaufman, Jr. v. Commissioner of Social Security · filed 2020-12-03(a)
The Court is persuaded by the Commissioner’s extensive caselaw, which establishes that the Sixth Circuit, and various district courts, have repeatedly found that an ALJ need not base their RFC determination on a medical opinion.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an ALJ to assess residual functional capacity using all relevant evidence and does not require reliance on any particular medical opinion.
Hogan v. Commissioner of Social Security · filed 2020-12-09(a)(1)
An ALJ is not required to rely on any particular opinion in formulating the claimant’s RFC. ... Rather, the ALJ is to assess the claimant’s RFC “based on all the relevant evidence in your case record.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).Read the full opinion on CourtListener →
Section 404.1545 does not require additional RFC limitations for an impairment when the claimant identifies no resulting functional limitation or supporting medical evidence.
Mann v. Commissioner of Social Security · filed 2020-12-09(a)(3)
Bonnie M. has not alleged any functional limitations caused by those impairments, nor has she provided any medical evidence that shows the condition was worse than the ALJ found. The ALJ did not err in finding her mesh implant and removal to be a non-severe impairment that did not require further limitations in the RFC.Read the full opinion on CourtListener →
Section 404.1545 requires a useful assessment of functional limitations when the medical record does not permit a commonsense RFC determination.
Johnson v. Commissioner of Social Security · filed 2020-12-11(a)
The medical evidence detailed above demonstrates that the record in this case is not one on which the ALJ could have reached a commonsense RFC determination based on minor physical impairments. Nor is it a record on which the ALJ could reach an RFC determination without some useful functional assessment of plaintiff’s limitations.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment based on all relevant evidence, including limitations from symptoms, and may require further record development when the evidence does not adequately address those limitations.
Brotherton v. Social Security Administration Commissioner · filed 2020-12-18(a)
RFC is the most that a person can do despite that person’s limitations. 20 C.F.R. §404.1545(a)(1). It is assessed using all relevant evidence in the record. ... The Court believes remand is necessary for the ALJ to more fully and fairly develop the record regarding Plaintiff’s RFC.Read the full opinion on CourtListener →
An ALJ may omit a claimed need to elevate a leg from the residual functional capacity when the claimant provides no medical evidence supporting that limitation.
Pack v. SSA · filed 2020-12-23(a)(3)
Because Mr. Pack did not include medical evidence supporting the claim that he needed to elevate his leg, it was reasonable for the ALJ not to include that specific limitation in the RFC. See 20 C.F.R. § 404.1545(a)(3); see also Jordan v. Comm’r of Soc. Sec., 548 F.3d 417, 423 (6th Cir. 2008) (holding that the claimant bears the burden of proving an RFC that is more restrictive than the ALJ’s determination).Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as what a claimant can do despite physical or mental limitations.
Smith v. Saul · filed 2021-01-29(a)
The Regulations define RFC as “what [the claimant] can do” despite his “physical or mental limitations.” 20 C.F.R. § 404.1545(a). ... Accordingly, the Court finds that remand is required because the ALJ’s RFC determination is not supported by substantial evidence.Read the full opinion on CourtListener →
Residual functional capacity must be based on all relevant evidence and supported by substantial evidence.
Salvas v. Saul · filed 2021-02-10(a)(1)
The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... The ALJ’s RFC is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a)(3) does not require a medical opinion for every residual functional capacity determination, but the determination must be supported by substantial evidence.
Rogers v. Social Security Administration, Commissioner of · filed 2021-02-08(a)(3)
This Court does not hold that an ALJ must always consider medical-opinion evidence in making an RFC determination—only that such determinations must be supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC assessment supported by evidence of the claimant’s functional limitations; medical opinions undermined by later evidence cannot provide substantial support for that assessment.
(SS) Johnson v. Commissioner of Social Security · filed 2021-02-26(a)
Because the evidence before the ALJ undermined the limitations imposed by Drs. Khong and Tayloe—as implicitly acknowledged by the more restrictive postural limitations identified by the ALJ—their opinions are not substantial evidence in support of the RFC.Read the full opinion on CourtListener →
Section 404.1545 requires an ALJ to assess residual functional capacity using all relevant evidence; a medium-work finding without evidence supporting the required lifting capacity warrants remand.
Vrlaku v. Commissioner of Social Security · filed 2021-03-05(a)(3)
Remand is also warranted because the ALJ’s RFC determination is not supported by substantial evidence. ... “[A]n ALJ must assess a claimant’s exertional capabilities—which includes the ability to stand and carry—based on ‘all of the relevant medical and other evidence[.]’” Sanders v. Comm’r of Soc. Sec., 506 F. App’x 74, 77 (2d Cir. 2012) (summary order) (quoting 20 C.F.R. § 404.1545(a)(3)); ... The ALJ’s conclusion that the plaintiff could perform work at a medium level is not supported by the evidence in the record. Thus, remand is warranted.Read the full opinion on CourtListener →
An RFC assessment does not necessarily require a medical opinion when the record contains sufficient evidence to assess the claimant’s functional capacity.
McKean v. Commissioner of Social Security · filed 2021-03-15(a)(1)
Where the record contains sufficient evidence from which an ALJ can assess a plaintiff’s RFC, a medical source statement or formal medical opinion is not necessarily required.Read the full opinion on CourtListener →
An ALJ generally cannot determine residual functional capacity by interpreting raw medical findings without a supporting medical opinion.
Manuel P. v. Saul · filed 2021-03-12(a)(1)
When an ALJ substitutes herownjudgment for that of the opining medical professionals, remand is required; an ALJ is simply not qualified to interpret raw medical data in functional terms whenno medical opinion supports the determination.Read the full opinion on CourtListener →
A residual functional capacity assessment must link a claimant’s work limitations to evidence of what the claimant can still do despite impairments.
Hines v. Saul · filed 2021-03-17(a)
In this case, the Court finds that the ALJ linked his RFC assessment—that is, a range of light work with limitations—to specific evidence in the record bearing upon Hines’ ability to perform the physical, mental, sensory and other requirements of work.Read the full opinion on CourtListener →
An ALJ’s residual functional capacity assessment must account for the medical evidence or explain the basis for its functional limits; an unexplained assessment warrants remand.
Williams v. Commissioner of Social Security · filed 2021-03-17
In this case, despite assigning various weights to the opinions of record, the ALJ did not account for the limitations – or lack thereof – contained in the opinions. Rather, she formulated an RFC that was completely divorced from the assessments reflected in each of the opinions of record.Read the full opinion on CourtListener →
An ALJ may not interpret raw medical data to determine a claimant’s residual functional capacity.
Kramer v. Commissioner of Social Security · filed 2021-03-17
As mentioned above, as a lay person, the ALJ is not permitted to interpret raw medical data when evaluating a claimant’s functional capacity.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to assess physical residual functional capacity without requesting an additional medical opinion when ample medical evidence already supports the assessment.
Buchanan v. Commissioner of Social Security · filed 2021-03-29
Consequently, the Court finds that the ALJ did not commit legal error by declining to request additional medical opinion evidence, and the ALJ’s determination of Plaintiff’s physical RFC is supported by substantial evidence.Read the full opinion on CourtListener →
Residual functional capacity may be assessed without a medical opinion specifying each restriction when the record contains enough evidence to assess the claimant’s abilities.
Rawls v. Commissioner of Social Security · filed 2021-03-29(a)(3)
Further, although there was no medical opinion providing the specific restrictions reflected in the ALJ's RFC determination, such evidence is not required when “the record contains sufficient evidence from which an ALJ can assess the [claimant's] residual functional capacity.” Cook v. Comm’r of Soc. Sec., 818 F. App’x 108, 109–10 (2d Cir. 2020) (citing Tankisi v. Comm’r of Soc. Sec., 521 F. App’x 29, 34 (2d Cir. 2013); Rosa v. Callahan, 168 F.3d 72, 79 n.5 (2d Cir. 1999) (internal quotation marks omitted)).Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires an RFC grounded in evidence of functional abilities; specific limits for a complex impairment lack substantial support when the record contains no functional assessment.
Griggs v. Commissioner of Social Security · filed 2021-03-22(a)(1)
Consistent with the foregoing, this Court finds that the RFC is not supported by substantial evidence because there is no functional assessment anywhere in the record.Read the full opinion on CourtListener →
Section 404.1545(a)(3) allows an ALJ to assess residual functional capacity from the relevant evidence without matching a medical opinion exactly.
Panfil v. Commissioner of Social Security · filed 2021-04-16(a)(3)
Contrary to plaintiff’s argument, the ALJ’s RFC did not need to perfectly correlate with an opinion of record.Read the full opinion on CourtListener →
An RFC assessment is supported when the evidence relied on by the ALJ, including medical evidence, provides substantial evidence of the claimant’s functional capacity.
Brown v. Saul · filed 2021-03-31(a)(1)
The Court finds that the evidence relied upon by the ALJ constitutes substantial evidence, including medical evidence, to support the RFC assessment. The ALJ considered the objective medical evidence, including the results of imaging and other testing, and findings on examination. He also properly weighed the opinion evidence.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to be supported by some medical evidence of the claimant’s ability to function in the workplace.
Brown v. Berryhill · filed 2021-03-31
As a result, the ALJ’s RFC assessment was not supported by “some medical evidence” that addressed her ability to function in the workplace.Read the full opinion on CourtListener →
Section 404.1545(a)(3) permits an RFC assessment based on all relevant evidence, including medical findings and daily activities, without a medical opinion.
Goepel v. Commissioner of Social Security · filed 2021-04-21(a)(3)
Contrary to plaintiff's argument, see Dkt. No. 10-1 at 14, the RFC finding need not be based on a medical opinion, but can be based on other evidence, such as medical findings and activities of daily living.Read the full opinion on CourtListener →
Section 404.1545(a)(3) permits an ALJ to assess residual functional capacity without a medical opinion when the record contains sufficient evidence of the claimant’s functional abilities.
Frost v. Commissioner of Social Security · filed 2021-06-03(a)(3)
Therefore, contrary to Plaintiff’s assertion, the ALJ did not err in formulating an RFC absent a medical opinion. Although the record was sparse, it contained more than a mere scintilla evidence from which the ALJ could formulate an RFC.Read the full opinion on CourtListener →
Residual functional capacity measures what a claimant can still do despite limitations; an ALJ may assess it without a formal medical opinion when the record contains sufficient evidence.
Rankin v. Commissioner of Social Security · filed 2021-06-10(a)(1)
Where the record contains sufficient evidence from which an ALJ can assess a plaintiff’s RFC, a medical source statement or formal medical opinion is not necessarily required.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to include in a claimant’s residual functional capacity only work-related limitations supported by the record evidence.
Kosanke v. Saul · filed 2021-06-24(a)(1)
The ALJ properly included only those work-related limitations she found supported by the record evidence, and adequately accounted for those limitations by limiting Plaintiff to light work and concluding that she could return to her past relevant work as a secretary, which is a sedentary exertional level position.Read the full opinion on CourtListener →
An ALJ may assess residual functional capacity without a specific medical opinion when the record contains sufficient evidence.
Nachar v. Commissioner of Social Security · filed 2021-06-28(a)(3)
Moreover, an ALJ’s RFC determination is not fatally flawed merely because it was formulated absent a medical opinion. ... Therefore, Plaintiff’s assertion that the ALJ’s RFC determination was the product of legal error because it was not supported by a specific medical opinion is without merit.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an ALJ assessing a claimant’s physical and mental work abilities to consider medical opinions with the rest of the relevant evidence.
Jones v. Commissioner, Social Security Administration · filed 2021-07-09(a)(3)
When determining the extent of a claimant's ability to do physical and mental work activities, the relevant regulations require the ALJ to consider medical opinions together with the rest of the relevant evidence in the record. 20 C.F.R. §§ 404.1545(a)(3), 416.945(a)(3). The ALJ has done just that.Read the full opinion on CourtListener →
An RFC finding must account for moderate limitations in concentration, persistence, and pace; limiting a claimant to simple and routine tasks alone is insufficient.
Culver v. Kijakazi · filed 2021-07-13
In light of the ALJ’s explicit finding that Culver had moderate limitations in concentration, persistence, and pace, it was necessary to account for those limitations in the RFC finding. Limiting Culver to tasks that are simple and routine was insufficient.Read the full opinion on CourtListener →
An ALJ’s residual functional capacity assessment may be affirmed when substantial evidence supports its conclusions about the claimant’s remaining work capacity.
Phillips v. Saul · filed 2021-07-13(a)(1)
Upon review, the Court finds substantial evidence supports each conclusion in the RFC. For example, the ALJ’s finding of Phillips’ high functioning activities (i.e., driving, cooking, fishing, going to church, and teaching third grade class) supports the conclusion that Phillips is capable of medium work.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 caused by impairments.
Yanes v. Commissioner, Social Security Administration · filed 2021-07-15(a)(1)
The SSA’s regulations define RFC as “the most [a claimant] can still do despite [the] limitations” caused by the claimant’s impairments. 20 C.F.R. § 404.1545(a)(1). ... Thus, substantial evidence supports the ALJ’s determination that Yanes could perform medium work.Read the full opinion on CourtListener →
Residual functional capacity describes what a claimant can do on a regular and continuing basis despite impairments.
Benthin v. Saul · filed 2021-07-15(b)
A social security disability claimant’s RFC assessment is an indication of what the claimant can do on a “regular and continuing basis” despite their impairments. ... The ALJ’s RFC determination is supported by substantial evidence in the record.Read the full opinion on CourtListener →
An RFC assessment may be supported by objective medical findings and other medical evidence even without a medical opinion.
Hurst v. Saul · filed 2021-07-16
It is true that an ALJ cannot draw their own inferences about a claimant’s functional ability simply from medical reports, Combs v. Berryhill, 878 F.3d 642, 646 (8th Cir. 2017), but, as Plaintiff acknowledged, see Doc. [15] at 9, objective medical findings and other medical evidence can constitute sufficient medical support for an RFC assessment even in the absence of medical opinion evidence.Read the full opinion on CourtListener →
Section 404.1545(c) requires an ALJ to assess work-related mental abilities and account for supported limitations when determining residual functional capacity.
Padilla v. Social Security Administration · filed 2021-07-19(c)
In formulating the RFC, an ALJ must perform a function-by-function assessment of these work-related functions, considering all of the relevant evidence in the case record.Read the full opinion on CourtListener →
Section 404.1545(a) requires an RFC to reflect what a claimant can do despite limitations, including limitations that arise on days when symptoms worsen.
Collins v. Commissioner of Social Security · filed 2021-07-19(a)
In other words, the ALJ’s RFC here is not “the most [Plaintiff] can do despite [his] limitations,” 20 C.F.R. § 404.1545(a), but the most he can do on the few days when he is at his best. This is not the standard.Read the full opinion on CourtListener →
Section 404.1545 requires the ALJ to consider all relevant evidence when assessing residual functional capacity, but does not require the assessment to repeat every limitation in a medical opinion exactly.
BERKHEIMER v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-07-19(a)(3)-(4)
Thus, the ALJ was not required to include each of the five “limited but satisfactory” mental abilities/aptitudes into the RFC exactly as described by PA Yingling.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires an RFC assessment to consider all relevant medical and other evidence, including a claimant’s description of limitations.
Turner v. Kijakazi · filed 2021-07-20(a)(3)
The RFC is based on all relevant medical and other evidence in the record and may include a claimant’s own description of limitations arising from alleged symptoms.Read the full opinion on CourtListener →
Section 404.1545 requires residual functional capacity to be determined from all relevant medical and other evidence in the case record.
King v. Kijakazi · filed 2021-07-22(a)(1), (a)(3)
The RFC is determined “based on all the relevant evidence in [the] case record[,]” including “all of the relevant medical and other evidence.” 20 C.F.R. §§404.1545(a)(1), (3), 416.945(a)(1), (3). The Court finds that the ALJ’s RFC determination is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1545(a) requires the ALJ to evaluate medical evidence, including descriptions of limitations, when determining a claimant’s capacity for work despite impairments.
Ruditsky v. Saul · filed 2021-07-26(a)
Plaintiff does not demonstrate that the ALJ failed to properly evaluate the medical evidence (including the claimant’s and others’ descriptions of limitation and medical reports) to determine what capacity the claimant has for work despite his or her impairment(s). 20 C.F.R. §§ 404.1545(a), 416.945(a).Read the full opinion on CourtListener →
An ALJ must explain a specific sit/stand limitation in a residual functional capacity assessment with evidence from the record sufficient for meaningful judicial review.
Hayes v. Commissioner of Social Security · filed 2021-07-15
Critically, the ALJ did not adequately explain why she assessed the specific and less restrictive sit/stand option that she did, despite affording “weight” to that aspect of Dr. Lurie’s opinion, and it is not clear what evidence in the record, if any, supports the ALJ’s determination. The absence of explanation for the specific sit/stand option assessed frustrates meaningful judicial review – that is, whether the highly specific RFC is supported by substantial evidence – and warrants remand.Read the full opinion on CourtListener →
An RFC finding need not account for alleged functional limitations supported only by self-reports and a medical opinion the ALJ reasonably found unpersuasive.
Roche v. Kijakazi · filed 2021-07-19(a)(1)
Because the ALJ reasonably found that Roche’s self-reports and Broderick’s opinions were not persuasive the ALJ did not err by failing to explicitly discuss these alleged limitations or to account for them in her RFC finding.Read the full opinion on CourtListener →
An RFC assessment must have a medical opinion supporting the functional limitations the ALJ assigns.
Aliza Wolf v. Saul · filed 2021-07-28(a)(1)
An ALJ must have a medical opinion to support his or her RFC.Read the full opinion on CourtListener →
An ALJ may assess residual functional capacity without a medical source statement or medical expert.
Wilkie v. Commissioner of Social Security · filed 2021-08-09(a)
However, as the Commissioner notes, neither the Social Security Act nor the regulations requires there to be a medical source statement in the file before an ALJ can make a decision. An ALJ is entitled to assess medical evidence even without the aid of a State agency medical consultant or medical expert.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.
(SS) Rubio v. Commissioner of Social Security · filed 2021-08-12(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)(1) defines residual functional capacity as the most a claimant can still do despite her limitations; the ALJ may assess her ability to remain on task as part of it.
Claudio v. Saul · filed 2021-08-12(a)(1)
The Residual Functional Capacity evaluation, or RFC, is an assessment of “the most [Plaintiff] can still do despite [her] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... Nor does she explain why this particular portion of the RFC should fall within the purview of a vocational expert - who would ordinarily have no information or expertise regarding a claimant's ability to stay on task - rather than an ALJ. In any event, this cursory argument does not warrant reversal.Read the full opinion on CourtListener →
Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider the entire record, including nonsevere impairments and resulting limitations.
Conner v. Saul · filed 2021-08-12(a)
In determining RFC specifically, an ALJ must consider the entire record, opinion evidence, impairments that are not severe, and any limitations the ALJ finds.Read the full opinion on CourtListener →
An ALJ must explain how the evidence supports the claimant’s residual functional capacity, including the assessment of claimed limitations.
Hall v. Saul · filed 2021-08-13
Before assigning an RFC, the ALJ’s “assessment must include a narrative discussion describing how the evidence supports each conclusion, citing specific medical facts (e.g., laboratory findings) and nonmedical evidence (e.g., daily activities, observations).” Monroe v. Colvin, 826 F.3d 176, 189 (4th Cir. 2016) (quoting Mascio, 780 F.3d at 636). ... The Court finds the ALJ provided a full analysis to support his finding that Hall’s testimony was inconsistent with the record, as well as the analysis to support the conclusion that Hall retained the RFC to perform light work.Read the full opinion on CourtListener →
An ALJ bases a claimant’s residual functional capacity on all relevant medical and other evidence in the record.
Quinn v. Commissioner of Social Security · filed 2021-08-16(a)(3)
An ALJ bases their RFC determination on “all of the relevant medical and other evidence” in the case record. Id. (a)(3).Read the full opinion on CourtListener →
Section 404.1545(a) requires the ALJ to assess residual functional capacity using all relevant, credible evidence, including medical records, observations, and the claimant’s description of his limitations.
Zinselmeier v. Saul · filed 2021-08-16(a)
The ALJ bears the primary responsibility for assessing a claimant’s RFC based on all relevant, credible evidence in the record, including medical records, the observations of treating physicians and others, and the claimant’s own description of his symptoms and limitations.Read the full opinion on CourtListener →
An ALJ may describe a claimant’s exertional abilities by using a defined category such as sedentary work without separately stating each exertional limit.
Blue v. Commissioner of Social Security · filed 2021-08-17
As in Terry, the Court finds that the ALJ’s reference to “sedentary work” as defined in the regulations adequately defines Claimant’s exertional abilities, given that SSR 83-10 defines “sedentary work” to require, inter alia, mostly sitting, but up to two hours standing/walking, and lifting no more than 10 pounds at one time.Read the full opinion on CourtListener →
Section 404.1545(a)(1) requires residual functional capacity to account for all of a claimant’s medically determinable impairments based on the relevant evidence.
Hagele v. Commissioner of Social Security · filed 2021-08-24(a)(1)
An RFC is based on all of a claimant’s medically determinable impairments: ... 20 C.F.R. § 404.1545(a)(1). The ALJ’s RFC finding was supported by substantial evidence for the reasons stated above, and so, fully accounted Hagele’s impairments.Read the full opinion on CourtListener →
Residual functional capacity is the most a claimant can still do despite impairments and related symptoms; the ALJ assesses it by weighing the evidence of the claimant’s limitations.
Andrews v. Saul · filed 2021-08-30(a)(1)
RFC is the most the claimant can still do despite her impairments and any related symptoms. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... In this case, the ALJ clearly considered all of the evidence related to Andrews’ ability to adapt and manage, and weighed the evidence accordingly to determine his RFC, limiting Andrews to only occasional interaction with the public.Read the full opinion on CourtListener →
Section 404.1545(a) requires consideration of relevant evidence when assessing residual functional capacity, but does not require inclusion of impairments without supported functional limitations.
Bryant v. Commissioner of Social Security · filed 2021-08-30(a)
As noted, however, the ALJ need not include unsupported findings or impairments without functional limitations in either the RFC or hypotheticals posed to the vocational expert.Read the full opinion on CourtListener →
Section 404.1545(a) requires the ALJ to assess residual functional capacity using all relevant medical and other evidence, not just medical opinions.
Gomez v. Commissioner of Social Security · filed 2021-08-30(a)
The ALJ “will assess your residual functional capacity based on all of the relevant medical and other evidence,” not just medical opinions. 20 C.F.R. § 404.1545(a).Read the full opinion on CourtListener →
Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations, so an RFC assessment describes maximum capacity rather than minimum ability.
Vigil v. Kijakazi · filed 2021-08-31(a)
As mentioned above, 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, any suggestion that the reviewing physicians RFC assessment stated an opinion about the minimum Plaintiff could do is far from reasonable and contrary to the definition of an RFC.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires the ALJ to consider medical source statements and all other record evidence when determining what a claimant can still do despite her limitations.
Hendricks v. Commissioner of Social Security · filed 2021-08-31(a)(3)
The Administrative Law Judge makes this finding based on a consideration of medical source statements and all other evidence in the case record. 20 C.F.R. §§ 404.1529, 404.1545(a)(3), 404.1546(c).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite impairments.
Hubbard v. Social Security Administration, Commissioner of (TV2) · filed 2021-08-31(a)(1)
A claimant’s RFC is the most the claimant can do despite his or her impairments. 20 C.F.R. § 404.1545(a)(1).Read the full opinion on CourtListener →
Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite impairments.
Love v. Kijakazi · filed 2021-09-01(a)(1)
To the contrary, substantial evidence supports the conclusion that the speed of these jobs is within his ability. See 20 C.F.R. § 404.1545(a)(1); SSR 96-8p (a claimant’s RFC is the most the claimant can do despite his impairments, not the least).Read the full opinion on CourtListener →
Section 404.1545(a) requires consideration of all relevant evidence and impairments that may cause functional limitations when assessing residual functional capacity.
Estes v. Commissioner of Social Security · filed 2021-09-01(a)
In formulating the RFC, the ALJ must consider all impairments that may cause functional limitations. Id.; 20 C.F.R. §§ 416.945(a)(1), (3); 20 C.F.R. §§ 404.1545(a), 416.945(a) (requiring consideration of “all the relevant evidence in [a] case record”).Read the full opinion on CourtListener →
Section 404.1545(a)(3) permits an ALJ to assess residual functional capacity without adopting a physician’s opinion verbatim, while prohibiting the ALJ from substituting a lay medical judgment.
Armington v. Commissioner of Social Security · filed 2021-08-16(a)(3)
Similarly, “[a]lthough the ALJ may not substitute his opinion for that of a physician” in fashioning an RFC, the ALJ “is not required to recite the medical opinion of a physician verbatim in his [RFC] finding.” Poe, 342 F. App’x at 157 (citing 20 C.F.R. § 404.1545(a)(3)).Read the full opinion on CourtListener →
In determining residual functional capacity, the ALJ considers the claimant’s impairments and symptoms in light of the objective medical evidence and may omit cane use when the record does not establish that it is medically required.
Williams v. Commissioner of Social Security · filed 2021-09-03(a)(2), (a)(3)
In formulating the RFC, the ALJ must consider all of the 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). ... Substantial evidence therefore supports the ALJ’s decision to omit the need to use a handheld assistive device from the RFC finding.Read the full opinion on CourtListener →
An RFC assessment must rest on relevant evidence showing how the claimant’s impairments affect the ability to work.
Huffman v. Commissioner, Social Security Administration · filed 2021-09-03(a)(1)
“The ALJ makes an RFC determination based on all the relevant medical and other evidence in the record,” Gonzales v. Colvin, No. 3:15-cv-0685-D, 2016 WL 107843, at *9 (N.D. Tex. Jan. 11, 2016) (citing 20 C.F.R. § 404.1545(a)(1)), ... The Court concludes that the ALJ’s physical RFC finding is not supported by substantial evidence and the ALJ’s failure to consider the opinion of a treating or examining physician to help her determine Plaintiff's physical RFC is material and prejudicial.Read the full opinion on CourtListener →
An RFC need not include an alleged limitation that the evidence does not support.
Harris v. Commissioner of Social Security · filed 2021-09-22(a)(3)
There is no objective medical evidence that Doretha H.’s conditions were so severe that nebulizing treatment was required every 4 hours. As such, the ALJ did not err when he did not accommodate this alleged limitation in the RFC.Read the full opinion on CourtListener →
An RFC assessment of physical abilities must be supported by a medical opinion or a function-by-function analysis connecting the medical evidence to the assessed capacity.
Martinez v. Commissioner of Social Security · filed 2021-09-29(b)
Without reliance on a medical source’s opinion or a function-by-function assessment connecting the medical evidence to the RFC, the ALJ’s decision leaves the Court with many unanswered questions and does not afford an adequate basis for meaningful judicial review.Read the full opinion on CourtListener →
Section 404.1545 permits an ALJ to omit a claimed work-absence limitation from residual functional capacity when the evidence supports discounting the claimed symptoms.
Munro v. Commissioner of Social Security · filed 2021-09-24
She therefore permissibly excluded a limitation regarding work absences from the RFC.Read the full opinion on CourtListener →
An RFC assessment need not include off-task or absenteeism limitations when those limitations would not affect the jobs the claimant can perform.
GEPNER v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-09-29(a)
Thus, the lack of specific limitations for being off-task or absent in the RFC is not error for three reasons. One, no off-task or absenteeism limitation in the RFC was necessary because Plaintiff’s limitations in these areas did not exceed an employer’s tolerance level.Read the full opinion on CourtListener →
An ALJ assesses residual functional capacity from all relevant medical and other evidence; a medical opinion is unnecessary when the record provides sufficient evidence for the assessment.
Wiles v. Commissioner of Social Security · filed 2021-10-14(a)(3)
The ALJ will assess plaintiff’s RFC based on all of the relevant medical and other evidence. Id. § 404.1545(a)(3). ... Contrary to Plaintiff’s assertion, an RFC determination is not fatally flawed merely because it was formulated absent a medical opinion.Read the full opinion on CourtListener →
Specific residual functional capacity limitations must be grounded in medical evidence rather than the ALJ’s lay judgment.
Hughes v. Commissioner of Social Security · filed 2021-11-18
Perhaps most basically, the ALJ erred in formulating very specific limitations in the RFC from whole cloth without any medical support.Read the full opinion on CourtListener →
Section 404.1545 requires an RFC assessment to consider all relevant medical and other evidence.
Hoyles v. Commissioner of Social Security · filed 2021-12-01(a)(3)
An RFC assessment will be “based on all of the relevant medical and other evidence.” Id. § 404.1545(a)(3). ... Therefore, the Court finds substantial evidence supports the ALJ’s RFC and remand is not warranted on this ground.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires the Commissioner to assess residual functional capacity using all relevant medical and other evidence, including the claimant’s testimony.
Bailey v. SSA · filed 2021-12-07(a)(3)
The Commissioner’s assessment is based upon all of the relevant medical evidence and other evidence in the record, including the claimant’s testimony.Read the full opinion on CourtListener →
Section 404.1545(a)(3) requires the ALJ to assess residual functional capacity using all relevant medical and other evidence.
Hansen v. Saul · filed 2021-12-07(a)(3)
The RFC determination is a legal decision rather than a medical one, and the development of a claimant’s RFC is solely within the province of the ALJ who considers “all of the relevant medical and other evidence” when making a finding. 20 C.F.R. § 404.1545(a)(3); see also 20 C.F.R. §§ 404.1527(e), 404.1546.Read the full opinion on CourtListener →
Section 404.1545 measures residual functional capacity by what a claimant can do despite credible limitations.
Purnell v. Kijakazi · filed 2021-12-10
Last, the Court is satisfied that the objective record evidence detailed above constitutes substantial evidence to support the RFC for a range of medium work, with the stated restrictions. Residual functional capacity is a measure of what Plaintiff can do despite his credible limitations. See 20 C.F.R. § 404.1545.Read the full opinion on CourtListener →
Notes 5101–5250 of 6,798, oldest cases first.
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