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

20 C.F.R. § 404.1545

Residual functional capacity: the cases that interpreted this section

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No reviewed case has held this section invalid, preempted, superseded or repealed.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

9,670 citing cases reviewed of 11,963 in the citation index: 6,798 interpreted the section (annotated below), 2,872 cited it only in passing. Cases filed after 2026-06-18 may not have been reviewed yet.

Have a situation under 20 C.F.R. § 404.1545?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Combined impairments

Section 404.1545 requires the Secretary to consider physical abilities, mental impairments, and other impairments when assessing the extent of disability.

Judy CASS, Plaintiff-Appellant, v. Donna E. SHALALA, Secretary of Health and Human Services, Defendant-Appellee · filed 1993-10-27

In determining the extent of Plaintiffs disability, the Secretary must consider the physical abilities,. mental impairments and any other impairments. 20 C.F.R. §§ 404.1545; 416.945.
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Section 404.1545 requires an ALJ to analyze the cumulative effect of all of a claimant’s impairments.

Claussen v. Chater · filed 1996-10-29

The ALJ must also analyze the cumulative effect of all of a claimant’s impairments. See 20 C.F.R. § 404.1545.
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Section 404.1545 requires the ALJ to consider the combined effect of multiple impairments, regardless of their severity, when assessing residual functional capacity.

Burnett v. Commissioner of Social Security Administration · filed 2000-07-25

Burnett is correct that the ALJ must consider the combined effect of multiple impairments, regardless of their severity. See 20 C.F.R. § 404.1545.
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Section 404.1545(a) requires the ALJ to consider all of a claimant’s impairments when assessing residual functional capacity.

Spears v. Barnhart · filed 2002-03-28(a)

The ALJ was, therefore, required to consider all of her impairments when assessing her RFC.
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Residual functional capacity must account for all of a claimant’s impairments, including subjective symptoms such as pain.

Johnson v. Barnhart · filed 2002-10-24(a)

In evaluating a claimant’s residual functional capacity, the ALJ is obliged to consider all of the claimant’s impairments, including subjective symptoms such as pain.
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Section 404.1545 requires the Commissioner to consider all of a claimant's impairments when determining what the claimant can still do.

Fastner v. Jo Anne B. Barnhart · filed 2003-04-03

In determining what a claimant's residual functional capacity is, the Commissioner looks at all of the claimant's impairments to determine what she can still do. 20 C.F.R. §§ 404.1545, 416.945. Accordingly, the ALJ was considering all of Fastner's impairments in determining his residual functional capacity: organic mental disorder, seizures, anxiety, alcohol dependence, history of closed head injury, headaches, and diminished hearing.
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Section 404.1545(a) requires consideration of all known impairments when assessing residual functional capacity.

Spicer v. Barnhart · filed 2003-05-05(a)

The Social Security Administration regulations clearly state that where an individual has more than one impairment, “we will consider all of [the] impairment(s) of which we are aware.” Id.
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Section 404.1545(a) requires consideration of all known impairments when assessing residual functional capacity.

Blood v. Comm Social Security · filed 2003-11-14(a)

And the ALJ did not refer to any evidence regarding Blood’s wrist injury, while the applicable regulations require an ALJ to “analyze the cumulative effect of all the claimant’s impairments in determining whether she is capable of performing work and is not disabled.” Plummer v. Apfel, 186 F.3d at 428 (citing 20 C.F.R. § 404.1523); see also 20 C.F.R. §§ 404.1545(a), 416.945(a) (“If you have more than one impairment, we will consider all of your impairment(s) of which we are aware.”).
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An RFC assessment must consider the combined effects of multiple impairments, regardless of severity.

Taylor v. Barnhart · filed 2007-02-21(a)(2)

As part of the RFC analysis, “the ALJ must consider the combined effects of multiple impairments, regardless of severity.”
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Section 404.1545(a)(2) requires consideration of all of a claimant’s impairments when determining residual functional capacity.

Robinson v. Barnhart · filed 2006-12-11(a)(2)

The ALJ, however, failed to consider these impairments in determining Plaintiffs RFC. This constitutes legal error.
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Section 404.1545(a) requires the ALJ to consider all of a claimant’s impairments, including subjective symptoms such as pain, when assessing residual functional capacity.

McCants v. Astrue · filed 2007-03-29(a)

In evaluating a claimant's residual functional capacity, the ALJ is obliged to consider all of the claimant's impairments, including subjective symptoms such as pain.
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Section 404.1545(e) requires the ALJ to consider the combined effect of a claimant’s impairments when assessing whether the claimant can perform past work.

Flaherty v. Astrue · filed 2007-10-03(e)

At step four, the ALJ must consider whether the claimant’s “impairment or combination of impairments prevents [her] from performing [her] past work.” Grogan, 399 F.3d at 1261 (quotation omitted); accord 20 C.F.R. § 404.1545(e).
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Section 404.1545(e) requires the ALJ to consider the combined effect of a claimant’s impairments when assessing residual functional capacity.

Flaherty v. Astrue · filed 2008-02-04(e)

At step four, the ALJ must consider whether the claimant’s “impairment or combination of impairments prevents [her] from performing [her] past work.” ... Furthermore, the ALJ’s discussion of the evidence and his reasons for his conclusions demonstrate that he considered all of Ms. Flaherty’s impairments.
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Section 404.1545(e) requires a residual functional capacity assessment to consider medication side effects and all impairments in combination, whether severe or not.

Rabadi v. Astrue · filed 2008-06-23(e)

This finding was in error because the ALJ failed to take into consideration the side effects of his medication and all of his impairments, whether severe or not, in combination.
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Section 404.1545(a) requires the ALJ to consider all relevant evidence when assessing a claimant’s capacity to meet a job’s physical, mental, sensory, and other demands.

Adkins v. Astrue · filed 2009-09-28(a)

Looking at all the relevant evidence, the ALJ must consider the claimant’s ability to meet the physical, mental, sensory and other demands of any job. 20 C.F.R. §§ 404.1545(a) and 416.945(a) (2006). ... Therefore, the undersigned finds that contrary to the Commissioner’s argument, it was not evident that the ALJ considered Claimant’s bipolar disorder when he assessed her RFC.
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Section 404.1545(a) requires residual functional capacity to account for the combined effect of a claimant’s impairments.

Stanley v. Astrue · filed 2010-07-15(a)

“[T]he regulations define [residual functional capacity] as that which an individual is still able to do despite the limitations caused by his . . . impairments.” Phillips v. Barnhart, 357 F.3d 1232, 1238 (11th Cir. 2004) (citing 20 C.F.R. § 404.1545(a)). ... Substantial evidence does not support that finding because the administrative law judge failed to account for the combined effect of all of Stanley’s impairments.
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Section 404.1545(e) requires the Commissioner to consider all impairments when assessing residual functional capacity, whether or not they are severe.

O'DELL v. Astrue · filed 2010-09-08(e)

The Commissioner is required to consider all impairments when making an RFC evaluation, regardless of whether or not those impairments are determined to be severe.
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Section 404.1545 requires the Administration to consider all known medically determinable impairments when assessing residual functional capacity.

Emanuele v. Astrue · filed 2011-03-17(a)(2), (e)

The Administration must consider all of the claimant’s known, medically determinable impairments when assessing RFC.
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Section 404.1545 requires consideration of all known, medically determinable impairments when assessing residual functional capacity.

McMurtry v. Astrue · filed 2010-10-27(a)(2), (e)

The Administration must consider all of the claimant’s known, medically determinable impairments when assessing RFC. § 404.1545(a)(2), (e).
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An RFC assessment considers impairments and related symptoms that may limit what a claimant can do at work; the ALJ need not include alleged limitations that the evidence does not support.

Qualls v. Astrue · filed 2011-07-01(a)(1)

This involves consideration of the claimant’s “impairment(s), and any related symptoms . . . [that] may cause physical and mental limitations that affect what [the claimant] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1). ... We also reject Ms. Qualls’ contention that the ALJ’s hypothetical to the VE erroneously omitted “all the limitations of record, even the nonsevere ones.” ... Accordingly, we conclude that the ALJ’s hypothetical adequately reflected the “impairments and limitations that [were] borne out by the evidentiary record,” and that Ms. Qualls has not identified any reversible error in the ALJ’s decision to deny benefits at step four of the sequential evaluation process.
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Residual functional capacity assessments consider the total limiting effects of a claimant’s medically determinable impairments, including their cumulative effect.

Priel v. Astrue · filed 2011-12-23(e)

The ALJ’s RFC determination was based upon an evaluation of both medical and non-medical evidence and the “total limiting effects” of Priel’s medically determinable impairments. 20 C.F.R. §§ 404.1545(e), 416.945(e). In these circumstances, Priel’s contention that the ALJ failed to consider the cumulative effect of all of his impairments is without merit.
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Section 404.1545 requires the agency to consider all known, medically determinable impairments when assessing residual functional capacity.

Freeman v. Astrue · filed 2011-09-16(a)(2), (e)

The Administration must consider all of the claimant’s known, medically determinable impairments when assessing RFC.
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Section 404.1545(a)(2) requires an RFC assessment to consider all medically determinable impairments, including a mental impairment found severe at step two.

Palomares v. Astrue · filed 2012-08-13(a)(2)

It is legal error for the ALJ to omit Mr. Palomares’ depression in the RFC analysis or the hypothetical to the VE in making his findings.
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An RFC assessment must consider limitations from medically determinable impairments even when those impairments are not classified as severe.

Sanchez v. Commissioner of Social Security · filed 2013-02-08(a)(1)–(3)

Before reaching step four, the ALJ must assess the claimant’s RFC—which is the most work the claimant can do despite her physical and mental limitations—by considering all of the relevant medical and medically determinable impairments, including any such impairments that are not “severe.” ... Moreover, both the ALJ’s RFC assessment and the hypothetical questions posed to the VE accounted for all of Sanchez’s mental limitations, including any limitations and symptoms that might have been caused by or were consistent with BPD.
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Section 404.1545 requires the ALJ to consider all of a claimant’s impairments when assessing residual functional capacity.

Cumella v. Colvin · filed 2013-03-26(e)

In making this finding, the ALJ must consider all of the- claimant’s impairments, including those which are not severe. 20 CFR §§ 404.1545(e) and 416.945(e). ... After finding fibromyalgia to be one of Ms. Cumella’s severe impairments, the ALJ is required to take fibromyalgia into consideration when determining her RFC. See Pirtle v. Astrue, 479 F.3d 931 at 935 (8th Cir.2007). The ALJ failed to do so.
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Section 404.1545 requires an RFC assessment to consider all relevant evidence of the claimant’s functional limitations, including limitations arising from obesity.

Shilo v. Colvin · filed 2014-02-28(a)

The Court also finds the ALJ appropriately considered, in his RFC finding and written decision, all of Plaintiffs functional limitations, whether arising from Plaintiffs obesity or otherwise.
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Section 404.1545 requires consideration of the combined effects of a claimant’s impairments when assessing residual functional capacity.

Green v. Colvin · filed 2015-03-13

Next Green contends that the ALJ erred in determining her residual functional capacity. Green accuses the ALJ of not considering the combined effects of her impairments, including her headaches and the pain in her shoulders, arms, and fingers. But the ALJ did consider these impairments and rejected them as non-disabling.
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Section 404.1545(a)(2) requires an ALJ assessing residual functional capacity to consider findings of mental impairments and related functional limitations.

Curtis v. Commissioner of Social Security Administration · filed 2014-07-30(a)(2)

In analyzing Curtis’ RFC on remand, the ALJ must, as required by 20 C.F.R. § 404.1545(a)(2), consider his own findings that Curtis suffered from severe depression and anxiety and had mild or mild to moderate limitations in several functional domains.
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Section 404.1545(e) requires an ALJ to consider all of a claimant’s impairments when assessing residual functional capacity.

Glenn v. Comm'r of Social Security · filed 2014-08-13(e)

The ALJ’s decision to expressly exclude consideration of one of Glenn’s ailments was improper under the requirement that an ALJ consider all of a claimant’s impairments. See 20 C.F.R. § 404.1545(e).
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An RFC assessment must consider evidence of an impairment even if the ALJ did not find it severe at step two.

Robinson v. Colvin · filed 2014-07-11(a)(2)

Additionally, though the ALJ failed'to consider plaintiffs migraines when determining which of her impairments were severe at step two, the evidence of migraines in the record was still required to be considered when formulating plaintiffs RFC. 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545(a)(2) requires the Commissioner to consider all medically determinable impairments when assessing residual functional capacity.

Burrell v. Colvin · filed 2015-02-18(a)(2)

Rejecting this argument as well, the magistrate judge observed that the ALJ found Burrell’s alleged side-effects to be medically indeterminable. See 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2) (providing that Commissioner will formulate RFC by considering all medically determinable impairments). ... We agree with the magistrate judge’s cogent analysis, and augment it only to reference the substantial evidence underlying the ALJ’s adverse credibility finding.
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An ALJ must consider a claimant’s ailments in combination when assessing residual functional capacity, but an ailment warrants a work limitation only when evidence shows how it affects the claimant’s ability to work.

Capman v. Colvin · filed 2015-07-01(a)(2)

While an ALJ must consider all the claimant’s ailments in combination and may not ignore lines of evidence, see 20 C.F.R. § 404.1545(a)(2); Thomas v. Colvin, 745 F.3d 802, 807 (7th Cir.2014); Villano v. Astrue, 556 F.3d 558, 563 (7th Cir.2009), Capman submitted no evidence to show how these particular ailments affected his ability to work.
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An RFC assessment considers the combined effects of a claimant’s impairments and all credible evidence, and includes only credible limitations.

Frank v. Colvin · filed 2015-09-08(a)

In conclusion, the court finds that when determining Plaintiffs RFC, as required by the. Regulations and case law, the ALJ considered the combination of Plaintiffs impairments, and based his RFC determination on all the credible evidence of record. To the extent. Plaintiff suggests the ALJ failed to include in Plaintiffs RFC limitations beyond those which the ALJ found credible, a claimant’s RFC need only include his credible limitations.
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Section 404.1545(e) requires the ALJ to consider all of a claimant’s alleged impairments when determining residual functional capacity.

Jacobus v. Commissioner of Social Secur · filed 2016-10-18(e)

Substantial evidence supported the ALJ’s RFC assessment, as the medical evidence was largely consistent with the assessment. 20 C.F.R. §§ 404.1545(e), 416.945(e) (providing the ALJ must consider all of a claimant’s alleged impairments in determining the claimant’s RFC).
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Section 404.1545 requires an RFC assessment to include all of a claimant’s impairments.

Bennett v. Colvin · filed 2016-08-16

In an RFC assessment, the ALJ must include all of a claimant’s impairments.
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In assessing residual functional capacity, the agency must consider all medically determinable impairments and assess whether they cause functional limitations, even when an impairment was found severe at step two.

Johnson v. Berryhill · filed 2017-02-15(a)(2)

Given this framework, although the ALJ found at step two that Johnson’s fibromyalgia was a severe impairment, he was still required to assess whether it presented additional functional limitations affecting her RFC.
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An ALJ may account for mental impairment evidence in the RFC assessment even when the decision discusses that evidence in its Step Two analysis.

Williams v. Berryhill · filed 2018-02-28(a)

However, Williams does not advance any argument claiming error on this basis, and the substance of the Step Two section of the opinion shows that the mental impairment evidence of record was also considered in the Step Four analysis.
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Section 404.1545 requires the ALJ to consider all impairments when assessing residual functional capacity, including limitations supported by the record.

Dauer v. Berryhill · filed 2018-09-26(e)

In making this finding, the ALJ must consider all the claimant’s impairments, including those which are not severe. 20 CFR § 404.1545(e). ... The ALJ’s RFC fails to properly consider plaintiff’s fecal incontinence and the intermittent and unanticipated resulting chronic diarrhea.
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Section 404.1545(e) requires the ALJ to assess whether a claimant’s mental impairment limits work-related activities when determining residual functional capacity.

Armata v. Berryhill · filed 2018-10-04(e)

Second, if the ALJ found that Plaintiff's anxiety did not meet or equal a listed impairment at step three, when crafting the RFC, the ALJ was required to analyze whether Plaintiff's mental impairment limited her ability to carry out work-related mental activities.
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Section 404.1545(a)(2) requires an ALJ to consider a claimant’s impairments individually and in combination when determining residual functional capacity.

Lemay v. Berryhill · filed 2018-10-18(a)(2)

As this Court noted before, an ALJ must consider all of a claimant’s impairments, alone and in combination with one another. See supra, § A. An RFC determination is no different. See 20 C.F.R. § 404.1545(a)(2); see also Richison v. Astrue, 462 Fed. App’x 622, 626 (7th Cir. 2012).
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An RFC need not include a restriction for every impairment found severe at step two.

Gebben v. Berryhill · filed 2019-03-12

These inquiries are different and the Court rejects Ms. G’s argument that the ALJ was obligated to include restrictions in the RFC to specifically correspond to each severe impairment identified at step two.
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An RFC assessment must address a claimant’s functional limitations or explain why they are discounted.

Tuttle v. Berryhill · filed 2019-03-18(a)(1)

The Court finds that the ALJ adequately accounted for Plaintiff’s inability to stay on task in assessing her RFC, but the ALJ did not discuss and either account for or discount her sensitivity to light, her professed need to lie down until her migraines subsided, or how the variable effectiveness of Botox injections caused the severity and limiting effects of her symptoms to wax and wane.
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Section 404.1545 requires the ALJ to assess residual functional capacity based on the combined effects of limitations supported by the record.

Terry v. Berryhill · filed 2019-08-02

This step calls for the ALJ to assess Plaintiff’s Residual Functional Capacity (“RFC”) to work despite the combined effects of all of their limitations supported by the record. 20 C.F.R. § 404.1545. ... After taking the above factors and others required by 20 C.F. R. § 404.1529(c)(1)–(3) into account, substantial evidence supports the ALJ’s properly determined finding of Plaintiff’s RFC.
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An ALJ assessing residual functional capacity must consider the combined effect of all medically determinable impairments, whether severe or not.

Sandoval v. Commissioner, Social Security Administration · filed 2019-08-02(a)(2)

An ALJ's omission of an impairment altogether could be reversible error. ... see also Wells v. Colvin, 727 F.3d 1061, 1069 (10th Cir. 2013) (citing 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2)) (“In his RFC assessment, the ALJ must consider the combined effect of all medically determinable impairments, whether severe or not.”) (emphasis in original). ... With that in mind and after review of the record, the Court finds that Plaintiff fails to demonstrate any error, and that ALJ Lawritson, in forming the RFC, properly addressed all of Plaintiff’s impairments and explained his reasoning in discrediting some of her limitations.
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An RFC must account for the combined impact of a claimant’s impairments.

Sellers v. Commissioner of Social Security · filed 2019-08-20(a)(2), (e)

Although this may be accurate, an RFC must take into account the combined impact of Plaintiff’s impairments. See 20 C.F.R. § 404.1545(a)(2) & (e).
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Section 404.1545(e) requires the Commissioner to consider the combined effect of all of a claimant’s impairments when determining residual functional capacity.

Elliott v. Social Security Administration · filed 2019-09-30(e)

When determining a claimant’s residual functional capacity (“RFC”) at steps four and five, the Commissioner must consider the combined effect of all the claimant’s impairments, mental and physical, exertional and non-exertional, severe and non-severe. 42 USS.C. §§ 423(d)(2)(B), (5)(B); Glenn v. Comm’r of Soc. Sec., 763 F.3d 494, 499 (6th Cir. 2014) (citing 20 C.F.R. § 404.1545(e)).
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Section 404.1545 requires the ALJ to consider impairments together when assessing residual functional capacity, including impairments that are not severe on their own.

Cosby v. Saul · filed 2019-10-23

Key to the instant analysis is the principle that an ALJ is required to consider the impairments both singly and in concert with one another when assessing a claimant’s RFC. ... While the ALJ discussed each of Claimant’s impairments individually, he failed to consider and articulate the combined effect of all of her impairments, including a discussion about how, collectively, those impairments might in fact hinder her ability to function in a full time work setting.
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Section 404.1545(a)(2) requires consideration of combined impairments in assessing residual functional capacity, but a claimant who identifies no additional limitations from their combined effect does not show material error.

Condon v. Saul · filed 2019-12-30(a)(2)

However, she has not identified any additional limitations stemming from her combined impairments. Condon, therefore, has not demonstrated that the ALJ committed a material error of law on this issue.
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Section 404.1545(e) requires the ALJ to consider the cumulative effect of a claimant’s impairments when assessing work capacity.

Hamed v. Berryhill · filed 2020-01-13(e)

If an individual has several impairments, the ALJ must consider their cumulative effect in making a disability determination.
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Section 404.1545 permits an ALJ to omit alleged combined limitations from the RFC when the record does not support them.

Raleigh v. Saul · filed 2020-01-22

There is little evidence that Plaintiff experiences five episodes of atrial fibrillation five days a week as she claims, or that she experiences a crippling anxiety that causes self-limiting behavior as a result of fear of an atrial fibrillation episode, such that would be prohibited from understanding, remembering, or applying information on a sustained basis. It is not an error for the ALJ to have concluded the same. Therefore, it is similarly not erroneous for the ALJ to have not accounted for these alleged limitations in combination with each other.
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Section 404.1545(a)(2) requires consideration of all impairments, including those that are not severe, when assessing residual functional capacity.

VILLALOBOS v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-01-07(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.
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Section 404.1545 requires an RFC assessment to account for functional limitations from all impairments, including those that are not severe.

Platkowsky v. Berryhill · filed 2020-01-14(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.”
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Section 404.1545(e) requires an ALJ assessing residual functional capacity to consider the limiting effects of every impairment, including impairments found not severe.

Williams v. Social Security Administration · filed 2020-01-17(e)

In reaching a determination regarding the claimant’s RFC, the ALJ must consider the limiting effects of all of the claimant’s impairments, not only those found to be “severe” at step two.
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Section 404.1545(a)(2) requires the ALJ to consider all impairments, including those found nonsevere, when assessing residual functional capacity.

MEDINA v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-01-23(a)(2)

The ALJ considers all impairments in this analysis, not just those deemed to be severe. ... Based on the ALJ’s thorough consideration of the objective medical record, the ALJ’s finding on Plaintiff’s RFC is supported by substantial evidence.
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Section 404.1545(e) requires the ALJ to consider the limiting effects of all impairments, including those that are not severe, when determining residual functional capacity.

Marcus v. Commissioner of Social Security · filed 2020-02-07(e)

It is well established the ALJ must consider the limiting effects of all of plaintiff’s impairments, including those that are not severe, in determining RFC.
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Section 404.1545 requires the ALJ to consider all record evidence, including the limiting effects of severe and non-severe impairments, when assessing residual functional capacity.

Rodriguez v. Commissioner of Social Security · filed 2020-02-10(a)(1)–(3)

In assessing a claimant’s RFC, the ALJ must consider all the evidence in the record, including the limiting effects of all documented impairments, regardless of whether those impairments are severe or non-severe.
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Section 404.1545(a)(3) requires an RFC assessment to consider all relevant evidence, including limitations from impairments that are not severe.

Butcher v. Saul · filed 2020-02-06(a)(3)

In crafting the RFC, the ALJ is required to consider the combination of all the claimant’s impairments, including those that are not severe.
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Section 404.1545 requires the ALJ to consider all impairments and their consistency with medical evidence when formulating residual functional capacity.

Harr v. Commissioner of Social Security · filed 2020-02-20(a)(2), (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); 416.945(a)(2), (e).
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including nonsevere ones, when assessing residual functional capacity.

(SS) Soto v. Commissioner of Social Security · filed 2020-02-25(a)(2)

The ALJ must consider “all of [a claimant’s] medically determinable impairments,” whether severe or not, when assessing an RFC.
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An RFC assessment considers all impairments, including those that are not severe.

DOUGE v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-02-25(a)(2)

The ALJ considers all impairments in this analysis, not just those deemed to be severe.
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An RFC assessment must consider the combined effects of all the claimant’s mental and physical impairments, including nonsevere impairments.

French v. Saul · filed 2020-03-10(e)

When determining the RFC, the ALJ must consider all of a claimant’s mental and physical impairments in combination, including those impairments that are severe and those that are nonsevere.
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An RFC assessment must account for supported limitations from all medical impairments, and the ALJ must explain how the assessment reflects those limitations.

Sapp v. Commissioner of Social Security · filed 2020-03-04

Additionally, on remand, the ALJ shall explain how his RFC determination, and hypothetical question to the VE, accommodate Ms. Sapp’s moderate limitation in concentration, persistence, or pace and how the RFC is substantially supported by the evidence, including all medical impairments.
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Section 404.1545(a) requires an RFC assessment to consider all relevant medical opinions and the combined effects of all impairments, including those that are not severe.

(SS) Eilts v. Commissioner of Social Security · filed 2020-03-11(a)

The ALJ must consider all of the relevant medical opinions as well as the combined effects of all of the plaintiff’s impairments, even those that are not “severe.”
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Section 404.1545(a)(2) requires the ALJ to consider the cumulative effects of medically determinable impairments, including those that are not severe.

Clark v. Commissioner of Social Security · filed 2020-03-13(a)(2)

... the ALJ must take into account the cumulative effects of ailments, including those that are non-severe. 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe.’”); accord Dixon v. Shalala, 54 F.3d 1019, 1031 (2d Cir. 1995).
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An ALJ may account for obesity in a residual functional capacity assessment by adopting medical opinion evidence that directly addresses it.

Petty v. Saul · filed 2020-03-20(a)(2)

By adopting medical opinion evidence that directly addressed Plaintiff’s obesity and found it imposed no additional impairments, such as that provided by Dr. Ocloo, it is clear the ALJ considered the impairment.
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Section 404.1545(a)(2) requires an ALJ to consider a claimant’s impairments when assessing residual functional capacity and explain why a severe impairment is omitted.

Glander v. Kijakazi · filed 2020-03-23(a)(2)

But the fact that the ALJ specifically identified “frequent urination” as a severe impairment yet omitted it from the RFC is just one factor supporting remand. Most significant is the ALJ’s failure to explain why she did not consider this impairment in her RFC determination.
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Residual functional capacity must account for all medically determinable impairments, whether severe or not.

(SS) Dodson v. Commissioner of Social Security · filed 2020-03-25(a)(2)

Likewise, this error impacted the residual ... functional capacity at step four, where an ALJ must which must include “all of [a claimant’s] medically ... determinable impairments,” whether severe or not. 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545 requires the ALJ to consider an impairment’s effects on a claimant’s ability to perform work-related functions when assessing residual functional capacity.

Aguero v. Berryhill · filed 2020-03-26(a)(1)-(3)

Because the ALJ did not reference this evidence in assessing Plaintiff’s RFC, it is unclear whether he accounted for the effects of her urinary incontinence on her ability to perform work-related functions as required by the regulations. See 20 C.F.R. § 404.1545(a)(1)-(3).
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Section 404.1545(a) requires an RFC assessment to consider the combined effects of a claimant’s medically determinable impairments, including those that are not severe on their own.

Oliver v. Commissioner of Social Security · filed 2020-03-31(a)

The RFC is a measure of what an individual can do despite the limitations imposed by her impairments. Young v. Barnhart, 362 F.3d 995, 1000 (7th Cir. 2004); 20 C.F.R. § 404.1545(a). ... Accordingly, remand is required for proper consideration of Plaintiff’s medically determinable impairments and the combined effects of these impairments, including her viral infection and chronic fatigue, even if the ALJ finds that these would not be considered severe in isolation.
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Section 404.1545(e) requires the ALJ to consider all of a claimant’s impairments, including those that are not severe, when assessing residual functional capacity.

Jensen v. Berryhill · filed 2020-03-31(e)

In making this finding, the ALJ must consider all of the claimant’s impairments, including those which are not severe. 20 CFR § 404.1545(e).
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe mental and physical impairments, when assessing residual functional capacity.

Collett-Brown v. Commissioner of Social Security · filed 2020-04-06(a)(2)

When determining the RFC, the ALJ must consider all medically determinable impairments, mental and physical, even those that are non-severe. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2); see also Craft, 539 F.3d at 676.
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Section 404.1545 requires an ALJ to consider all impairments, including those that are not severe, when assessing residual functional capacity.

CHURCH v. BERRYHILL · filed 2020-04-13(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. ... As a result, this Court finds that ALJ O’Leary properly analyzed the factual record and determined that Plaintiff met the definitional exertional requirements to perform sedentary work with some additional physical and mental limitations.
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Section 404.1545(a)(2) requires an RFC assessment to consider all medically determinable impairments together, including those that are not severe.

ROSSI v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-04-15(a)(2)

In formulating a claimant’s RFC, the ALJ is required to assess all of Plaintiff’s medically determinable impairments, both severe and not severe, in combination.
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Section 404.1545(e) requires consideration of the limiting effects of all impairments when assessing residual functional capacity; omitting a supported need for a cane can be harmful error.

Pigott v. Commissioner of Social Security · filed 2020-04-07(e)

The ALJ must consider the limiting effects of all of plaintiff’s impairments, including those that are not severe, in determining his RFC. ... The ALJ did not include the use of a cane in plaintiff’s RFC (AR 20), while failing to explain the rejection of this part of Dr. Weir’s report and plaintiff’s testimony. This was harmful error, as it was consequential to the ultimate disability conclusion.
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Section 404.1545(a) requires an ALJ to consider all impairments, including nonsevere impairments, when assessing residual functional capacity.

FRANCIS v. BERRYHILL · filed 2020-04-14(a)

In so doing, an ALJ makes a residual functional capacity (RFC)2 determination taking into consideration all impairments, including any impairment that is not severe.
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An RFC assessment considers all medically determinable impairments, including those found non-severe at step two.

Walter v. Berryhill · filed 2020-04-20(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.
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Section 404.1545 requires an RFC assessment to account for functional limitations from all impairments, including those that are not severe.

White v. Saul · filed 2020-04-29(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.”
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An ALJ assessing residual functional capacity must consider all medically determinable impairments, including those found non-severe at step two.

Lutz-Stoker v. Saul · filed 2020-05-08(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.
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Section 404.1545(a)(2) requires consideration of severe and non-severe medically determinable impairments together when assessing residual functional capacity.

GRZYBOWSKI v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-05-13(a)(2)

In determining Plaintiff’s RFC, the ALJ was required to consider all of Plaintiff’s severe impairments, in addition to her non-severe impairments, in combination.
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Residual functional capacity must account for all impairments, including those that are not severe.

GARDNER v. COMMISSIONER OF SOCIAL SECUIRTY · filed 2020-05-15(a)

In so doing, an ALJ makes a residual functional capacity determination taking into consideration all impairments, including any impairment that is not severe.
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Section 404.1545(e) requires consideration of limitations from a claimant’s impairments when assessing residual functional capacity, but does not require a separate discussion of each severe impairment’s limitations.

Cooper v. Saul · filed 2020-05-26(e)

According to Plaintiff, the ALJ violated the requirements set forth in Social Security Ruling (“SSR”) 96-8p and 20 C.F.R. § 404.1545(e), which require him to consider and include all limitations from Plaintiff’s impairments, including severe impairments. Neither of these provisions require the ALJ to address the limitations caused by each severe impairment individually, along with their respective impacts on the RFC, and Plaintiff has not identified any authority that does.
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Section 404.1545(a)(2) requires the RFC assessment to consider all medically determinable impairments together, including impairments that are not severe.

MORRIS v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-05-28(a)(2)

Additionally, the RFC assessment takes into consideration all of a claimant’s medically determinable impairments in combination, including those that the ALJ has found to be severe, as well as those that are not deemed to be severe at step two. See 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe,’ as explained in §§ 404.1520(c), 404.1521, and 404.1523, when we assess your residual functional capacity.”).
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Sincavage v. Berryhill · filed 2020-05-29(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including nonsevere ones, when assessing residual functional capacity.

French v. Saul · filed 2020-06-04(a)(2)

Second, the ALJ must consider all medically determinable impairments, whether severe or not, in assessing the claimant’s RFC.
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Section 404.1545(a)(2) requires the ALJ to consider all impairments when determining residual functional capacity, including impairments found not severe.

Reyes v. Saul · filed 2020-06-02(a)(2)

Finally, as long as the ALJ finds at least one severe impairment, she must proceed with the sequential evaluation and consider all impairments when determining the RFC. 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments when assessing residual functional capacity, including non-severe impairments.

Kshir v. Saul · filed 2020-06-11(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. §§404.1545(a)(2), 416.945(a)(2).
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An ALJ assessing residual functional capacity must consider all medically determinable impairments, including non-severe impairments.

Wheeler v. Saul · filed 2020-06-15(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. §§404.1545(a)(2), 416.945(a)(2).
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Section 404.1545 requires an ALJ to consider all of a claimant’s impairments when determining residual functional capacity, including impairments found not severe.

Hernandez v. Saul · filed 2020-06-16

An ALJ must consider all impairments in determining a claimant’s RFC, even those that are not severe.
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Section 404.1545(a)(1) requires the ALJ to consider a claimant’s impairments and related symptoms when determining residual functional capacity.

Holmes v. Berryhill · filed 2020-06-17(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).
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Section 404.1545(a)(2) requires consideration of all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Carrick v. Berryhill · filed 2020-06-22(a)(2)

In making this assessment, the ALJ considers all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545(a) requires an ALJ to consider relevant medical opinions and the combined effects of all impairments, including those that are not severe, when assessing residual functional capacity.

Lopez v. Berryhill · filed 2020-06-23(a)

The ALJ must consider all of the relevant medical opinions as well as the combined effects of all of the plaintiff’s impairments, even those that are not “severe.”
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Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider the entire record, including nonsevere impairments and mental limitations.

Satchell v. Saul · filed 2020-06-26(a)

Even if the claimant does not meet both the paragraph A and paragraph B criteria, the ALJ must still account for the claimant’s mental impairments in the RFC analysis. In determining RFC, an ALJ must consider the entire record, opinion evidence, impairments that are not severe, and any limitations the ALJ finds. 20 C.F.R. §§ 404.1545(a), 416.945(a) (ordering the ALJ to consider the entire record); SSR 96-8p, 1996 WL 374184, at *2 (defining the RFC as an assessment of an individual’s ability to perform vocational-related physical and mental activities).
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An RFC determination requires a useful assessment of the claimant’s functional limitations when the medical evidence does not permit a commonsense assessment based on minor physical impairments.

Bayer v. Commissioner of Social Security · filed 2020-06-26(a)

Nor is it a record upon which the ALJ could reach an RFC determination without some useful functional assessment of Bayer’s limitations. And yet that is precisely what the ALJ appears to have done by rejecting the only two medical opinions in the record. Accordingly, I find that the ALJ’s rejection of Vukas’s and Liu’s opinions – whether those rejections were proper or improper – effectively created an evidentiary gap in the record, and that no other useful functional assessment of Bayer’s limitations exists that would support the RFC determination. Remand is thus warranted for further development of the record.
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Residual functional capacity is what a claimant can still do despite limitations caused by impairments.

Stancavage v. Saul · filed 2020-06-29(a)(1)

RFC is defined as “that which an individual is still able to do despite the limitations caused by his or her impairment(s).”
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite limitations.

Fink v. Saul · filed 2020-07-01(a)(1)

A claimant’s RFC is “the most a claimant can do despite [the claimant’s] limitations.” Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009) (citing 20 C.F.R. § 404.1545(a)(1)); see also 20 C.F.R. § 416.945(a)(1). ... For all of the above reasons, the Court finds the Commissioner’s RFC finding was supported by substantial evidence.
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Section 404.1545 requires an RFC assessment to consider all relevant evidence of what a claimant can still do despite impairments.

Thompson v. Commissioner of Social Security · filed 2020-07-01(a)

Here, the ALJ’s decision considered all of the relevant evidence in forming Thompson’s RFC and did not “cherry-pick” it.
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Section 404.1545(a) requires an ALJ to include a non-severe mental impairment in residual functional capacity only when it imposes a functional limitation.

Stone, Jeffrey v. Berryhill, Nancy · filed 2020-07-02(a)

Moreover, the regulations only require an ALJ to incorporate a non- severe mental impairment into an RFC where such impairments impose a functional limitation. See SSR 96-8p; 20 C.F.R. § 404.1545(a) (defining RFC as a claimant’s impairment(s) “that affect what [the claimant] can do in a work setting”).
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Section 404.1545(a)(3) requires residual functional capacity to be determined from all relevant medical and other evidence.

(SS) Barone v. Commissioner of Social Security · filed 2020-07-09(a)(3)

“In determining a claimant's RFC, an ALJ must consider all relevant evidence in the record such as medical records, lay evidence and the effects of symptoms, including pain, that are reasonably attributed to a medically determinable impairment.” Robbins, 466 F.3d at 883. See also 20 C.F.R. § 404.1545(a)(3) (residual functional capacity determined based on all relevant medical and other evidence).
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Section 404.1545(a)(1) requires an ALJ to assess residual functional capacity using all relevant evidence, but treatment notes alone may not support the ALJ’s own medical conclusions about work limitations.

Smith v. Commissioner of Social Security · filed 2020-07-09(a)(1)

In determining whether this burden is met, the ALJ assesses the claimant’s RFC based on all the relevant medical and other evidence in the record. 20 C.F.R. §§ 404.1545 (a)(1), 416.945 (a)(1). ... And while the government correctly argues 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.
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Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite limitations, assessed using all relevant evidence.

McMinn v. Saul · filed 2020-07-10(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 regarding Plaintiff’s musculoskeletal impairments and limitations is supported by substantial evidence.
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Residual functional capacity reflects what a claimant can still do despite her limitations; obesity alone does not establish additional physical restrictions.

Melendez v. Berryhill · filed 2020-07-10(a)(1)

Plaintiff does not present any evidence demonstrating that she was unable to climb stairs, ladders, stoop, kneel, crouch, and crawl due to her obesity. Rather, she states that obesity should be evidence per se of an inability to engage in physical activities. (Pl. Br. 21.) The Court rejects this assertion.
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Section 404.1545(a)(1) defines residual functional capacity as the most an individual can still do despite limitations.

Keovilay v. Berryhill · filed 2020-07-15(a)(1)

An individual’s residual functional capacity (“RFC”) is the most an individual can still do despite his or her limitations. 20 C.F.R. § 404.1545(a)(1).
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Section 404.1545 requires an RFC determination to consider all relevant evidence, including medical sources’ diagnoses, treatment, observations, and opinions.

Banuelos v. Berryhill · filed 2020-07-16

However, 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.
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Section 404.1545(a)(2) requires the ALJ to consider all known medically determinable impairments when assessing residual functional capacity, including impairments that are not severe.

Bentley v. Saul · filed 2020-07-09(a)(2)

In assessing residual functional capacity, the ALJ is obligated to consider “all of [the claimant’s] medically determinable impairments of which [the ALJ is] aware, including [the claimant’s] medically determinable impairments that are not ‘severe.’” 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545(a)(2) requires an RFC determination to consider all of a claimant’s impairments, including those that are not severe.

Newman v. Saul · filed 2020-07-17(a)(2)

RFC determinations must consider all the claimant’s impairments (including severe and non-severe impairments). 20 C.F.R. § 404.1545(a)(2).
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An ALJ assessing residual functional capacity considers all medically determinable impairments, including non-severe impairments.

Bonner v. Saul · filed 2020-07-17(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. §§404.1545(a)(2), 416.945(a)(2).
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Section 404.1545(a)(2) requires consideration of all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Carswell v. Saul · filed 2020-07-20(a)(2)

An ALJ must consider all of a claimant’s impairments, severe and non-severe, in combination.
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Section 404.1545 requires an ALJ to consider all impairments, including nonsevere impairments, when assessing residual functional capacity.

Griffith v. Saul · filed 2020-08-03(a)(2)

An ALJ must consider all impairments in determining a claimant's RFC, even those that are not severe. ... Without consideration of Plaintiff's obesity and her severe impairments in conjunction with her obesity, the ALJ failed to apply the correct legal standard and paint a logical bridge from the evidence to the conclusion he reached regarding Plaintiff's RFC.
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Section 404.1545 requires the ALJ to consider all of a claimant’s impairments, including non-severe impairments, when assessing residual functional capacity.

Hoynoski v. Saul · filed 2020-08-05(a)(2)

In making this finding, the ALJ must consider all of the claimant's impairments, including those that are non-severe.
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Section 404.1545(a)(2) requires consideration of nonsevere medically determinable impairments when assessing residual functional capacity.

Thompson v. Commissioner of Social Security Administration · filed 2020-08-06(a)(2)

Though the ALJ found Plaintiff’s mental impairment to be non-severe, he was still required to consider its effects in formulating the RFC at step four.
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Section 404.1545(e) requires the ALJ to consider the limiting effects of all impairments, including those that are not severe, when assessing residual functional capacity.

SIECIENSKI-ANTINORO v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-08-12(e)

The ALJ must consider the limiting effects of all Plaintiff’s impairments, including those that are not severe. 20 C.F.R. § 404.1545(e).
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Section 404.1545(a)(2) requires an ALJ to consider all impairments, including non-severe impairments, when assessing residual functional capacity.

Bridgham v. Commissioner of Social Security · filed 2020-08-10(a)(2)

“The ALJ must consider all of the claimant’s impairments, including non-severe impairments, in assessing the claimant’s RFC.” ... Accordingly, the ALJ’s failure to address Claimant’s diagnoses of uncontrolled diabetes and peripheral neuropathy requires the Court to reverse and remand the matter for further proceedings.
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Section 404.1545(a)(2) requires an ALJ to account for limitations caused by medically determinable impairments, including non-severe impairments.

Newsted v. Commissioner of Social Security · filed 2020-08-12(a)(2)

An ALJ must account for all limitations caused by a claimant’s medically determinable impairments, even those that are non-severe, but Plaintiff has failed to meet his burden to show that his incontinence constituted a medically determinable impairment. See 20 C.F.R. § 404.1545(a)(2).
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An ALJ must consider the combined limiting effects of all medically determinable impairments, including impairments that are not severe, when assessing residual functional capacity.

Matthews v. Saul · filed 2020-08-20(a)(3), (e)

It is true that ALJs must consider the total limiting effects of all medically determinable impairments, including those that are not “severe.” 20 C.F.R. § 404.1545(a)(3), (e). But that is what the ALJ did here.
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In assessing residual functional capacity, the ALJ considers the limiting effects of all impairments, including those that are not severe.

Ray v. Commissioner of Social Security · filed 2020-09-01(e)

In determining a claimant’s RFC, the ALJ considers the limiting effects of all of the claimant’s impairments, even those that are not severe. 20 C.F.R. § 404.1545(e); SSR 96-8p, 1996 SSR LEXIS 5, *14, 1996 WL 374184, at *5. ... The ALJ’s decision in this case sufficiently complied with those standards.
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In assessing residual functional capacity, the ALJ must consider all of a claimant’s impairments, including those that are not severe.

Williams v. Commissioner of Social Security · filed 2020-09-08(e)

The ALJ should consider all the claimant’s impairments, including those that are not severe, in evaluating the claimant’s RFC.
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Section 404.1545(a)(2) requires an ALJ to consider all impairments, including non-severe impairments, when assessing residual functional capacity.

Wroda v. Social Security Administration · filed 2020-09-09(a)(2)

Indeed, an ALJ must consider all impairments, including those found to be non-severe, when assessing an RFC. 20 C.F.R. §§ 404.1545(a)(2), 404.1521(a).
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An RFC assessment must consider limitations and restrictions from all of a claimant’s impairments, including those that are not severe.

COUNIHAN v. SAUL · filed 2020-09-09(a)(2)

In assessing a claimant’s RFC, the ALJ must consider limitations and restrictions imposed by all of an individual’s impairments, including those that are not severe. 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545 requires the ALJ to consider all medically determinable impairments, including nonsevere impairments, and their limiting effects when assessing residual functional capacity.

Goff v. Commissioner of Social Security Administration · filed 2020-09-21(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.
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Haynes v. Saul · filed 2020-09-17(a)(2)

Additionally, in assessing RFC, the regulations direct to ALJ to “consider all of [the claimant’s] medically determinable impairments of which we are aware, including [those] medically determinable impairments that are not ‘severe’ . . . .” 20 C.F.R. § 404.1545(a)(2). ... Here, the ALJ did not discuss Plaintiff’s fibromyalgia or its effects at any step of the decision.
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Section 404.1545(a)(2) requires an RFC assessment to consider all medically determinable impairments together, including impairments that are not severe.

SHEPPARD v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-09-23(a)(2)

Additionally, the RFC assessment takes into consideration all of a claimant’s medically determinable impairments in combination, including those that the ALJ has found to be severe, as well as those that are not deemed to be severe at step two. See 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe,’ as explained in §§ 404.1520(c), 404.1521, and 404.1523, when we assess your residual functional capacity.”).
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Section 404.1545(a) requires an RFC assessment to consider all relevant medical opinions and the combined effects of all impairments, including those that are not severe.

(SS) Martin v. Commissioner of Social Security · filed 2020-09-24(a)

The ALJ must consider all of the relevant medical opinions as well as the combined effects of all of the plaintiff’s impairments, even those that are not “severe.” 20 C.F.R. §§ 404.1545(a); 416.945(a); Celaya v. Halter, 332 F.3d 1177, 1182 (9th Cir. 2003). ... Here, the ALJ’s RFC determination did not account for any limitation—let alone a moderate limitation—in the ability to perform work activities on a consistent basis, as opined by Dr. Richwerger. (Tr. at 23.) And the ALJ offered no reason for failing to credit Dr. Richwerger’s opinion with respect to this limitation. As such, the ALJ committed legal error.
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Section 404.1545(a)(1) requires the ALJ to consider a claimant’s impairments and related symptoms when determining residual functional capacity.

Schultz v. Commissioner of Social Security · filed 2020-09-25(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).
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Section 404.1545(a) requires an RFC assessment to consider the combined effects of all impairments, including those that are not severe.

(SS) Lee v. Commissioner of Social Security · filed 2020-09-29(a)

The ALJ must consider all of the relevant medical opinions as well as the combined effects of all of the plaintiff’s impairments, even those that are not “severe.” ... Moreover, defendant fails to cite to an example of the ALJ’s consideration of plaintiff’s mental impairment in determining the RFC—nor could the court find such an example. Accordingly, plaintiff’s is also entitled to summary judgment on the claim that the ALJ’s RFC determination was erroneous.
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Residual functional capacity must account for limitations from severe and non-severe impairments; failing to name a diagnosis does not require remand when the assessment incorporates its functional limitations.

Solomon v. Saul · filed 2020-09-29(a)(1)-(2)

Where—as here—a Plaintiff has at least one severe impairment, “the limiting effects of all” Plaintiff’s impairment(s) are considered in determining a Plaintiff’s residual functional capacity, including severe and non-severe impairments. ... The Court concludes that the ALJ incorporated functional limitations resulting from PTSD into the RFC and therefore, the failure to mention PTSD does not require reversal of the ALJ’s decision or remand.
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Section 404.1545(a) requires an RFC assessment to consider severe and non-severe impairments; inadequate consideration of a non-severe impairment can make a step-two error harmful.

RAINEY v. SAUL · filed 2020-10-08(a)

Thus, an ALJ will proceed to consider a plaintiff’s severe and non-severe impairments in the evaluation process in determining a plaintiff’s RFC. ... At step 5, despite acknowledgement that he must consider all evidence and all symptoms, both severe and non-severe, the ALJ’s discussion of Plaintiff’s fibromyalgia is scant. ... Based on the same, I find the ALJ unexplained inconsistency at step 2 may have infiltrated the remaining parts of the sequential analysis and cannot be considered harmless.
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Section 404.1545(a)(2) requires an RFC assessment to account for functional limitations from all medically determinable impairments, including mental impairments.

Galford v. Commissioner of Social Security · filed 2020-10-06(a)(2)

“A RFC determination must account for limitations imposed by both severe and nonsevere impairments.” Parker-Grose, 462 F.App'x at 18; see also 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware ... when we assess your [RFC]”).
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Section 404.1545(a)(2) requires an ALJ assessing residual functional capacity to consider the combined effects of all medically determinable impairments, severe and non-severe.

Womack v. Commissioner of Social Security · filed 2020-10-15(a)(2)

Thus, once a severe impairment is found, the administrative law judge must consider the “combined effect” of all the medically determinable severe and non-severe impairments in assessing a claimant’s RFC.
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An RFC assessment considers all of a claimant’s impairments, including impairments that are not severe.

HILL v. BERRYHILL · filed 2020-10-19(a)

In so doing, an ALJ makes a residual functional capacity (RFC)2 determination taking into consideration all impairments, including any impairment that is not severe.
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Section 404.1545(a)(2) requires an RFC assessment to consider all of a claimant’s impairments, including those that are not severe.

Pfitzer v. Saul · filed 2020-10-20(a)(2)

In making the RFC finding the ALJ must consider all of the claimant’s impairments, including impairments that are not severe.
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An ALJ must consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Friscone-Repasky v. Commissioner of Social Security · filed 2020-10-26(e)

Again, “for a Step Two error to be harmless—and therefore not subject to reversal—the ALJ must have actually considered the cumulative effect of all of the claimant’s impairments, severe and not severe, in assessing the claimant’s RFC.” Nejat, 359 F. App’x at 577. The ALJ’s decision here does not show he considered Plaintiff’s migraines in assessing the RFC.
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An ALJ must consider all of a claimant’s impairments when assessing residual functional capacity, including impairments that are not severe.

SILAS v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-10-27(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.
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Section 404.1545(a)(2) requires an RFC assessment to consider severe and non-severe impairments in combination.

MURPHY v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-11-30(a)(2)

The RFC analysis considers severe and non-severe impairments in combination. See 20 C.F.R. § 404.1545(a)(2).
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Section 404.1545 requires an RFC assessment to include functional limitations from all impairments, including those that are not severe.

Vader v. Social Security Administration · filed 2020-11-30(a)(1)-(2), (e)

An RFC must include an individual’s functional limitations or restrictions as a result of all of her impairments—even those that are not severe (see 20 C.F.R. § 404.1545(a)(1)-(2), (e))—and must assess her “work-related abilities on a function-by-function basis.” SSR 96-9p, 1996 WL 374184, at *1; see also Valentine v. Comm’r of Soc. Sec. Admin., 574 F.3d 685, 690 (9th Cir. 2009) (“an RFC that fails to take into account a claimant’s limitations is defective”).
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An RFC assessment may be found to consider impairments in combination when the ALJ says all symptoms were considered and discusses non-severe impairments.

Vanwormer v. Commissioner of Social Security Administration · filed 2020-11-30(a)

Second, although the ALJ may have only specifically addressed Vanwormer’s IBS in his off-task percentage calculation, the Sixth Circuit has repeatedly found that an ALJ considered all of a claimant’s impairments in combination when the ALJ notes that “all symptoms” were considered and non-severe impairments were discussed in analyzing the RFC. See Emard v. Comm’r of Soc. Sec., 953 F.3d 844, 851-52 (6th Cir. 2020). That is the case here.
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Section 404.1545(a)(2) requires an ALJ to consider the combined effect of all medically determinable impairments when assessing residual functional capacity, whether severe or nonsevere.

Henry v. Saul · filed 2020-12-01(a)(2)

In assessing a claimant’s RFC, an ALJ must consider the combined effect of all of the claimant’s medically determinable physical and mental impairments, whether severe or nonsevere.
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Section 404.1545(a)(2) requires the ALJ to consider all impairments, including those that are not severe, when assessing residual functional capacity.

FIRESTONE v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-12-14(a)(2)

The ALJ considers all impairments in this analysis, not just those deemed to be severe.
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Section 404.1545(a)(2) requires the RFC assessment to consider all medically determinable impairments together, including those that are not severe.

PENROSE v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-12-23(a)(2)

Additionally, the RFC assessment takes into consideration all of a claimant’s medically determinable impairments in combination, including those that the ALJ has found to be severe, as well as those that are not deemed to be severe at step two.
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Section 404.1545 requires the residual functional capacity assessment to consider evidence of all impairments and their combined effect on a claimant’s ability to function.

Braden v. Commissioner of Social Security · filed 2021-01-26

If not, the ALJ must then assess the claimant’s residual functional capacity, which is defined as the most a person can do despite any physical and mental limitations that may affect what can be done in a work setting. 20 C.F.R. §§ 404.1545, 416.945. ... While the exclusion of any discussion regarding these impairments or limitations on their own may not be enough for remand, taken all together they indicate that the ALJ did not fully examine all of Ms. Braden’s impairments or the combined effect they may have on her ability to function.
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Section 404.1545 requires the ALJ to consider all impairments and the medical evidence when assessing residual functional capacity.

Owens v. Commissioner of Social Security · filed 2021-02-19(a)(2), (e)

In formulating a claimant’s RFC, the ALJ must consider all impairments and the extent to which they are consistent with medical evidence. 20 C.F.R. §§ 404.1545(a)(2), (e); 416.945(a)(2), (e). ... Considering this — and that Plaintiff points to no evidence to the contrary — there is substantial evidentiary support of the ALJ’s determination that Plaintiff can return to light work with some limitations.
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An ALJ must consider all of a claimant’s impairments, severe and nonsevere, individually and together when assessing residual functional capacity.

Stephens v. Commissioner of Social Security Administration · filed 2021-02-22(a)(2)

The Court agrees that the ALJ must consider all of a claimant’s impairments—both severe and non-severe—singly and in combination, when formulating a claimant’s RFC.
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Section 404.1545(e) requires an ALJ to consider the combined limiting effects of all impairments and symptoms when assessing residual functional capacity, without assigning a separate limitation to each one.

Norton v. Saul · filed 2021-04-28(e)

Similarly, the ALJ “will consider the limiting effects of all [an individual’s] impairment(s), even those that are not severe, in determining [their] residual functional capacity.” 20 C.F.R. § 404.1545(e). The regulations specifically state, “[p]ain or other symptoms may cause a limitation of function beyond that which can be determined on the basis of the anatomical, physiological or psychological abnormalities considered alone.” Id. However, neither the regulations nor the caselaw require the ALJ to specifically separate individual impairments or symptoms within the residual functional capacity, because they are considered as a whole.
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Section 404.1545 requires an RFC assessment to consider the combined effect of a claimant’s mental and physical, exertional and nonexertional, severe and nonsevere impairments.

Button v. Social Security Administration · filed 2021-07-22

Determining a claimant’s limitations for purposes of establishing an RFC occurs in steps four and five of the sequential evaluation process and requires consideration of the combined effect of the claimant’s impairments: mental and physical, exertional and nonexertional, severe and nonsevere. See 42 U.S.C. § 423(d)(2)(B); 20 CFR §§ 404.1520, 404.1545, 416.920.
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Section 404.1545(a)(2) requires ALJs to consider the combined effect of all established impairments, severe and non-severe, when determining residual functional capacity.

BAYSINGER v. SAUL · filed 2021-07-29(a)(2)

ALJs are required to consider the combined effect of all established impairments—severe and non-severe—when they formulate a claimant’s RFC.
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Section 404.1545(e) requires an ALJ assessing residual functional capacity to consider the limiting effects of all impairments, including those that are not severe.

Stamper v. SSA · filed 2021-09-07(e)

The Social Security regulations, namely 20 C.F.R. § 404.1545(e), describes what the ALJ should take into account: “we will consider the limiting effects of all your impairment(s), even those that are not severe, in determining your residual functional capacity.”
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Section 404.1545(a)(2) requires the ALJ to consider all impairments when assessing residual functional capacity, including those deemed non-severe.

FRASCA v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-09-08(a)(2)

The ALJ considers all impairments in this analysis, not just those deemed to be severe. ... Second, the ALJ properly considered the medical opinions and MRIs when assessing Plaintiff’s residual functional capacity.
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Section 404.1545(e) requires an RFC assessment to consider the limiting effects of all impairments, including those that are not severe.

Fulmer v. Commissioner of Social Security · filed 2021-09-13(e)

The ALJ must consider the limiting effects of all of the claimant’s impairments, including those that are not severe, in assessing the RFC. 20 C.F.R. § 404.1545(e); SSR 96-8p. ... Although the ALJ included seizure precautions and limitations in the RFC, including limiting Plaintiff to less-skilled, lower stress work and providing restrictions against climbing, exposure to wetness, humidity, loud noise, excessive vibrations, and workplace hazards, heights, and driving (AR 19), the ALJ did not include limitations that account for Plaintiff’s loss of consciousness from a psychogenic seizure. ... For these reasons, the Court finds that the ALJ’s RFC and step five finding lack the support of substantial evidence.
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Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including those that are not severe, when assessing residual functional capacity.

McKenzie v. Kijakazi (CONSENT) · filed 2021-09-14(a)(2)

Based on Eleventh Circuit precedent, the court concludes that the ALJ’s statements demonstrate that the ALJ sufficiently considered all of Plaintiff’s impairments in combination in the rest of the sequential evaluation.
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Section 404.1545(e) requires an ALJ to consider the combined limiting effects of all of a claimant’s impairments when determining residual functional capacity, including impairments that are not severe.

Munoz v. Social Security Administration · filed 2021-09-21(e)

In making his RFC finding an ALJ must “consider the limiting effects of all [of a claimant’s] impairment(s), even those that are not severe, in determining [a claimant’s] residual functional capacity.” 20 C.F.R. § 404. 1545(e). ... Accordingly, the Court holds that the ALJ’s decision sufficiently reflects that he considered the combined limiting effect of Plaintiff’s impairments.
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An RFC assessment must consider the combined effect of bathroom breaks and concentration limitations on a claimant’s time off task.

Freed v. Kijakazi · filed 2021-09-20(a)(2)

If Freed’s mild impairment in concentration, persistence, and pace resulted in any time off task in addition to his time off task for bathroom breaks, this combination of limitations may preclude work. Therefore, remand is required to permit that ALJ to reassess the extent to which Freed may be off task during the workday, whether through the need for unscheduled bathroom breaks or limitations in concentration, persistence, or pace.
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Notes 451–600 of 6,798, oldest cases first.

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