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No reviewed case has held this section invalid, preempted, superseded or repealed.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.

Evidence considered in residual functional capacity

Residual functional capacity is the most a claimant can do despite physical or mental impairments, based on the relevant evidence of functional limitations.

Christensen v. Commissioner of Social Security Administration · filed 2022-09-01

The RFC is the most a person can do, despite her physical or mental impairments. See 20 C.F.R. § 404.1545. ... For the above reasons, the Court finds that the RFC determination is supported by substantial evidence.
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Section 404.1545(a)(3) requires the ALJ to assess residual functional capacity using all relevant medical and other evidence, even when no medical opinion addresses a particular exertional limitation.

Crews v. Saul · filed 2022-09-16(a)(3)

20 C.F.R. §§ 404.1546(c), 416.946(c), and the ALJ must formulate a claimant’s RFC based “on all of the relevant medical and other evidence,” 20 C.F.R. § 404.1545(a)(3).
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Section 404.1545(a)(3) requires the ALJ to assess residual functional capacity using all relevant medical and other evidence.

Sidor, Jr. v. Commissioner of Social Security · filed 2022-09-19(a)(3)

The ALJ must assess a claimant’s RFC “based on all of the relevant medical and other evidence.” 20 C.F.R. § 404.1545(a)(3).
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Residual functional capacity is the most a claimant can do despite the claimant’s limitations.

Carpenter v. Kijakazi · filed 2022-09-28(a)(1)

Prior to Step Four, the Commissioner must assess the claimant’s “residual functional capacity” (RFC), which is “the most a claimant can do despite [his or her] 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. § 404.1520(e). ... Having reviewed the entire record, the Court finds that the AL] made a proper RFC determination based on a fully and fairly developed record.
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Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations.

Pitts v. Commissioner of Social Security · filed 2022-09-28(a)

A claimant’s [RFC] is the most he or she can still do despite his or her limitations. ... Secondly, the ALJ addressed Plaintiff’s cane use in reaching the RFC. ... Thus, Plaintiff fails to show that his RFC was more limited than the ALJ found.
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An ALJ must base the residual functional capacity assessment on all relevant evidence in the record and explain the limitations it supports.

Leutik v. Kijakazi · filed 2022-09-30(a)(3)

An ALJ’s ability to make inferences regarding Plaintiff’s functional limitations caused by her impairments is not unlimited. It must be tied to the evidence in the record such that the ALJ’s RFC finding is based on all the relevant evidence in the record. See 20 C.F.R. § 404.1545(a).
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Residual functional capacity is based on all relevant evidence in the claimant’s record.

Hunter v. Saul · filed 2022-03-03(a)(1)

Before moving from step three to step four, the Commissioner determines the claimant’s residual functional capacity (“RFC”), which is “a determination of the most the claimant can still do despite his physical and mental limitations and is based on all relevant evidence in the claimant’s record.” Perez, 415 F.3d at 462 (citing 20 C.F.R. § 404.1545(a)(1)). ... Thus, Plaintiff’s argument that the ALJ failed to consider all of the medical evidence of record is without merit.
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Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite limitations and requires assessment based on all relevant case evidence.

White v. Commissioner of Social Security Administration · filed 2022-08-04(a)(1)

RFC refers to “the most [the claimant] can still do despite [his] limitations” and should be assessed “based on all the relevant evidence in [the] case record.” 20 C.F.R. §§ 404.1545(a)(1); 416.945(a)(1). ... Reading the portion of the ALJ’s decision Plaintiff cites in the context of that decision as a whole, the Court finds the ALJ did not err, and his mental RFC is supported by substantial evidence.
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An ALJ may assess residual functional capacity using all relevant record evidence, including a claimant’s statements, even when the resulting limitations differ from a medical opinion.

Riddle v. Commissioner of Social Security · filed 2022-08-09(a)(1)

The ALJ explained the reason for assigning an RFC with an exertional work level lower than opined by Cordum was due to Petitioner’s complaints of pain with exertional activities, citing Petitioner’s functional report and testimony. (AR 19.) This was an appropriate exercise of the ALJ’s responsibility to determine credibility, resolve conflicts in the testimony, and to translate and incorporate all of the relevant evidence in the record into a succinct RFC. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1); Rounds, 807 F.3d at 1006; Brown-Hunter, 806 F.3d at 492.
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Section 404.1545 requires an RFC assessment to consider all relevant medical and other evidence, including a claimant’s description of limitations.

Duncan v. Kijakazi · filed 2022-09-09(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. ... Based on the foregoing, the Court finds that the ALJ’s RFC determination is supported by substantial evidence.
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Section 404.1545 requires an ALJ to assess residual functional capacity using all relevant medical evidence and supported functional limitations.

STONEBRAKER v. KIJAKAZI · filed 2023-01-10(a)

Because the ALJ relied heavily on state agency assessments that did not review all of Claimant's medical evidence in forming her RFC, her RFC finding is unsupported.
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Section 404.1545(a)(3) bases residual functional capacity on all relevant medical and other evidence and permits consideration of a claimant’s description of symptom-related limits.

Ramirez v. Kijakazi · filed 2023-03-09(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.
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Residual functional capacity is the most a claimant can still do despite physical or mental limitations, and an assessment of light work must be supported by evidence of the claimant’s functional abilities.

Ackerman v. Saul · filed 2023-03-14(a)(1)

RFC is “the most [a claimant] can still do despite” his or her physical or mental limitations. 20 C.F.R. § 404.1545(a)(1). ... In making her determination, the ALJ did not explain how any evidence of record supported her assessment of light exertional level capability.
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Residual functional capacity measures the most a claimant can still do despite limitations and must be based on all relevant evidence in the case file.

Hall v. Commissioner of Social Security · filed 2023-03-24(a)(1)

A claimant’s RFC is an assessment of “the most [a claimant] can still do despite [her] limitations.” 20 C.F.R. § 404.1545(a)(1) (2012). A claimant’s RFC assessment must be based on all the relevant evidence in his or her case file. Id.; see also 20 C.F.R. §§ 404.1513(a), 404.1520c. Substantial evidence supports that Plaintiff would not have needed additional work limitations due to her Meniere’s disease.
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An RFC finding must be supported by evidence of the claimant’s functional ability to perform the work identified by the ALJ.

Usher v. Commissioner of Social Security · filed 2023-03-30

But here, not only does the record lack medical opinion evidence regarding Plaintiff’s functional capacity, the record also lacks any functional evidence supporting the RFC.
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An ALJ determines residual functional capacity by weighing the medical evidence and need not adopt any one provider’s assessment.

(SS) Pirro v. Commissioner of Social Security · filed 2023-04-26

Thus, as previously noted, it is squarely within the ALJ’s province to synthesize the medical evidence, resolve conflicts and ambiguities in the medical testimony, and determine credibility.
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Section 404.1545 requires the ALJ to assess residual functional capacity using relevant medical and other evidence in the record.

Pomales v. Commissioner of Social Security · filed 2023-05-02(c)

The ALJ dutifully considered all records, including even those outside of the relevant period, to determine the RFC based on all the relevant medical and other evidence of record.
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Section 404.1545(a) requires the ALJ to assess residual functional capacity using all relevant medical and other evidence; the finding need not match a single medical opinion.

Foote v. Commissioner of Social Security · filed 2023-05-25(a)

The ALJ “will assess your residual functional capacity based on all of the relevant medical and other evidence,” not just medical opinions.
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Section 404.1545(a)(1) bases residual functional capacity on all relevant evidence of what a claimant can still do despite limitations; speculative treatment absences need not be included.

(SS) Castro, Jr. v. Commissioner of Social Security · filed 2023-05-30(a)(1)

Accordingly, the ALJ did not err by failing to include time away from work for medical treatment in her assessment of Plaintiff’s RFC and the ALJ’s RFC determination was supported by substantial evidence. See 20 C.F.R. § 404.1545(a)(1).
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Residual functional capacity is the most a claimant can still do despite her limitations.

(SS) Grider v. Commissioner of Social Security · filed 2023-07-13(a)

As the ALJ’s RFC assessment is ultimately at issue here, the Court notes that a claimant’s RFC is “the most [a claimant] can still do despite [her] limitations.”
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The ALJ is responsible for determining residual functional capacity, rather than the claimant’s physician.

Driscoll v. Kijakazi · filed 2023-07-31

The ALJ did not err in formulating the residual functional capacity (“RFC’), ... and substantial evidence supports the ALJ’s RFC formulation.
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An ALJ may assess residual functional capacity without a treating source opinion when the record contains enough evidence to assess the claimant’s limitations.

Bailey v. Commissioner of Social Security · filed 2023-08-10(a)(1)

And the ALJ is entitled to reach an RFC finding without the opinion of a treating source as long as the record contains evidence from which the ALJ could assess plaintiffs limitations—such as treatment notes, physician’s findings, or testimony about plaintiffs activities of daily living.
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Section 404.1545(a)(1) requires an ALJ to assess residual functional capacity using all relevant evidence, including evidence of a claimant’s need for a walker.

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

The ALJ must evaluate RFC “based on all the relevant evidence in [the] case record.” 20 C.F.R. § 404.1545(a)(1). ... The ALJ’s conclusion Plaintiff does not require a walker was premised on the ALJ’s erroneous finding that one had not been prescribed.
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Residual functional capacity reflects the most a claimant can do despite physical and mental limitations and must include all limitations supported by the medical record.

HANKINS v. KIJAKAZI · filed 2023-09-11

The RFC is an indication of the most that the claimant can do in a work setting despite her mental and physical limitations and it must incorporate all of the claimant's limitations supported by the medical record.
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Section 404.1545 defines residual functional capacity as what a claimant can still do despite her limitations; the assessment must account for supported limits on sitting and standing.

Murray-Lee v. Commissioner of Social Security · filed 2023-09-15(a)(1)

The RFC assessment “is the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... Although the ALJ correctly observed that the term “too long” is not quantified and could be vague, the ALJ did not provide adequate and supported reasons for discounting the entirety of Ms. High’s direction in this regard. ... Because this issue is outcome determinative, the matter is due to be reversed and remanded for further consideration.
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Residual functional capacity is the most a claimant can still do despite limitations, including supported restrictions on hand use.

Calhoun v. Commissioner of Social Security · filed 2023-09-18(a)(1)

The RFC assessment “is the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... The ALJ generally found persuasive the non-examining opinions on Plaintiff’s lack of physical exertional limitations, but giving Plaintiff the benefit of the doubt, the ALJ restricted Plaintiff’s RFC to “only frequently handl[ing] and finger[ing] with the left hand.” Tr. at 24-25. The ALJ did not err in arriving at this conclusion.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations, based on all relevant evidence in the record.

Forgason v. Social Security Administration Commissioner · filed 2023-09-29(a)(1)

RFC is defined as “the most [a claimant] can still do despite [his] limitations . . . based on all the relevant evidence in [his] case record.” 20 C.F.R. § 404.1545(a)(1). ... After careful consideration, the Court finds that the medical evidence before the ALJ was sufficient to allow him to assess Mr. Forgason’s medical conditions and craft an appropriate RFC.
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An ALJ determines residual functional capacity from all relevant evidence in the record; a treating physician need not provide an opinion matching the RFC.

Birmingham v. Commissioner of Social Security Administration · filed 2023-09-29(a)

An individual’s RFC is defined as “the most [a claimant] can still do despite [her] limitations.” 20 C.F.R. §§ 404.1545(a)(1) & 416.945(a)(1). The ALJ is charged with determining a claimant’s RFC “based on all the relevant evidence in [a claimant’s] case record.” 20 C.F.R. §§ 404.1545(a) & 416.945(a).
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Section 404.1545(a)(1) requires an ALJ to assess what a claimant can still do despite limitations based on all relevant record evidence.

Hreha v. Commissioner of Social Security Administration · filed 2023-09-30(a)(1)

An ALJ assesses a claimant’s “residual functional capacity based on all the relevant evidence in [the] case record.” 20 C.F.R. § 404.1545(a)(1). ... For the reasons set forth above, and the Court finds Mr. Hreha has not met his burden to show that the RFC – which did not require elevation of his legs during the workday – lacked the support of substantial evidence.
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Section 404.1545(a)(3) requires the ALJ to assess residual functional capacity using all relevant medical and other evidence; the assessment need not mirror a medical opinion.

Harper v. Commissioner of Social Security · filed 2023-12-13(a)(3)

As stated previously, the ALJ has the responsibility to determine a claimant’s RFC, based on all of the relevant medical and other evidence in the record. To require that an RFC mirror a medical opinion would conflict with an ALJ’s duties.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite his limitations.

Brooks v. Social Security Administration, Commissioner of · filed 2024-01-09(a)(1)

The RFC is the most a claimant can do despite his limitations. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... Thus, the Court finds that the ALJ’s RFC determination was not inconsistent but rather complied with the requirements of the regulations.
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Section 404.1545 defines residual functional capacity as the most a claimant can still do despite their limitations.

Sierra v. Commissioner of Social Security · filed 2024-01-25(a)(1)

The RFC assessment “is the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... Having reviewed the ALJ’s findings and the record, the undersigned finds the RFC is supported by substantial evidence and need not be disturbed.
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Residual functional capacity is the most a claimant can still do despite physical or mental limitations.

Oliver v. O'Malley · filed 2024-02-02(a)(1)

The Court thus holds the ALJ did not err in formulating Plaintiff’s RFC and determining whether Plaintiff is disabled.
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Section 404.1545 requires an ALJ to assess a claimant’s residual functional capacity through a thorough consideration of evidence bearing on functional limitations.

Ferguson v. Commissioner of Social Security · filed 2024-02-07

Thus, the ALJ’s detailing of Claimant’s clinical records, including her treatment notes, reflects the fact the ALJ’s description of Claimant’s functional limitations was based on a thorough and holistic consideration of her clinical records.
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Residual functional capacity measures the most a claimant can still do despite limitations based on all relevant evidence; an ALJ may express a moderate mental limitation in different terms if the choice is adequately explained.

GROSSMANN v. COMMISSIONER OF SOCIAL SECURITY · filed 2024-02-29(a)(1)

An ALJ need only provide a “valid explanation” for how a claimant’s limitations informed the RFC. Hess, 931 F.3d at 211. The ALJ did so here.
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Residual functional capacity is the most a claimant can still do despite limitations.

Moon v. Commissioner of Social Security · filed 2024-03-04(a)(1)

The RFC assessment “is the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... Here, the ALJ adequately assessed Plaintiff’s subjective complaints of pain and urinary frequency, ultimately arriving at an RFC that is supported by substantial evidence.
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Section 404.1545(a)(3) requires an ALJ to consider all relevant medical and other evidence when assessing residual functional capacity, including records predating the alleged onset of disability.

Moy v. O'Malley · filed 2024-03-05(a)(3)

However, the ALJ is required under 20 C.F.R. § 404.1545(a)(3) to weigh all relevant medical and other evidence throughout the medical record. ... The ALJ’s review of how Ferida’s conditions allegedly developed, including medical visits prior to the alleged onset, what Ferida stated about her symptoms, and what the medical record exhibited when determining the RFC limitations was not an error.
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An ALJ must assess residual functional capacity using all relevant evidence, including medical evidence and descriptions of limitations caused by the claimant’s symptoms.

Turner v. Kijakazi · filed 2024-03-25(a)(1), (a)(3)

An ALJ assesses a claimant’s RFC “based on all the relevant evidence in [the] case record.” 20 C.F.R. § 404.1545(a)(1). The ALJ must consider both the medical evidence and “descriptions and observations of [the claimant’s] limitations from [the claimant’s] impairment(s), including limitations that result from [the claimant’s] symptoms” provided by the claimant, family, friends, and other people. Id. § 404.1545(a)(3). ... Here, because the ALJ erred in assessing the opinions of Ms. Whiting and Ms. Caveza and in assessing A.T.’s subjective testimony, his RFC finding is not supported by substantial evidence in the record.
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Section 404.1545 requires an ALJ to assess a claimant’s functional capacity, including the ability to reach, when determining residual functional capacity.

Abernathy v. Commissioner of Social Security · filed 2022-12-19

Moreover, the ALJ shall assess and provide a narrative discussion about plaintiff's functional capacity to perform reaching tasks generally and as an exertional demand required by the proposed representative occupations.
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Section 404.1545(a)(3) requires the ALJ to consider the record as a whole, including observations by providers who do not specialize in the claimant’s impairment.

Salazar v. Commissioner of Social Security Administration · filed 2023-03-07(a)(3)

Indeed, the duty of the ALJ is to consider the record as a whole. 20 C.F.R. § 404.1545(a)(3). At any rate, it was rational for the ALJ to rely upon those observations when evaluating the consistency factor.
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Medication effects on residual functional capacity

Section 404.1545(a)(1) requires the RFC to reflect limitations caused by impairments and related symptoms; the ALJ must develop the record when medication effects may affect those limitations.

Oehrlein v. Kijakazi · filed 2023-09-28(a)(1)

The Court specifically finds that the ALJ needed to develop the record enough to establish whether “[t]he type, dosage, effectiveness, and side effects of any medication [Plaintiff] take[s] or have taken to alleviate your pain or other symptoms” should have been reflected in his RFC limitations and thus should have impacted his ability to perform his past relevant work.6 20 C.F.R. §§ 404.1545(a)(1), 404.1529(c)(3). Because the ALJ failed to follow these regulations in reaching a disability determination at step four, the Court holds that the ALJ legally erred.
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Residual functional capacity must account for the limiting effects of pain when assessing a claimant’s ability to work.

Scott v. Shalala · filed 1995-08-10(e)

Rather, all of these considerations should go directly to determining whether the total limiting effects of pain might prevent the claimant from working in the national economy. 20 C.F.R. § 404.1545(e).
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Pain and other symptoms can limit a claimant’s work capacity beyond what objective findings alone show.

Carr v. McMahon · filed 2007-02-12(e)

Moreover, the Commissioner recognizes that pain and other subjective symptoms cannot be objectively measured and that the same physical impairment may produce differing levels of pain in different individuals.
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Treatment noncompliance in RFC assessments

An RFC assessment may not consider a claimant’s failure to follow prescribed treatment without applying the required treatment procedures.

Lanier v. Commissioner of Social Security · filed 2024-08-30

The law does not permit consideration of noncompliance with treatment as part of the residual functional capacity evaluation.
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Fluctuating symptoms in RFC assessment

An RFC assessment measures what a claimant can still do despite limitations; alleged symptom fluctuations do not require greater restrictions when the evidence does not support their claimed severity.

Winchester v. Commissioner of Social Security · filed 2024-09-23(a)(1)

The RFC assessment “is the most [a claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a)(1). ... Third, the ALJ did not fail to recognize the fluctuation in symptoms. Instead, the evidence in the file simply does not support the severity of the symptoms alleged during the relevant time period. The ALJ did not err.
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Sitting limitations in RFC assessments

Section 404.1545(b) requires an ALJ assessing physical residual functional capacity to evaluate functions including sitting.

Ralston v. Kijakazi · filed 2023-07-31(b)

Pursuant to SSR 96-8p, an ALJ’s RFC assessment must include an evaluation of the claimant’s ability to perform the physical functions listed in 20 C.F.R. § 404.1545(b), including “sitting, standing, walking, lifting, carrying, pushing, pulling, or other physical functions . . . [that] may reduce [a claimant’s] ability to do past work and other work.” 20 C.F.R. § 404.1545(b).
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Omitted limitations in residual functional capacity

A claimant challenging a residual functional capacity assessment must identify supported limitations the ALJ omitted and show resulting harm.

BILBY v. O'MALLEY · filed 2024-03-18(a)(1), (c)

The burden remains on Andrew B. to establish harm by identifying specific limitations that were supported by the evidence yet neglected by the ALJ. See Jozefyk v. Berryhill, 923 F.3d 492, 498 (7th Cir. 2019). Given the above considerations, the Court cannot agree that he has shown how his medically determinable impairments caused any limitations beyond those the ALJ found.
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An ALJ need include in a residual functional capacity assessment only limitations found reliable and consistent with the record.

Ramirez v. Commissioner Social Security Administration · filed 2024-10-22

An ALJ is only required to incorporate those limitations he finds to be reliable and consistent with the record.
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Notes 6751–6798 of 6,798, oldest cases first.

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