Reported / Citable
Background
A.C. sought disability insurance benefits and supplemental security income, alleging disability beginning March 19, 2019 based on conditions including a stroke, hypertension, anemia, depression, fatigue, insomnia, and related impairments. Her claims were initially denied, and an ALJ found her not disabled after a 2021 hearing. A prior federal-court action resulted in an unopposed remand to the agency.
Following an August 2024 hearing, the ALJ again found A.C. not disabled. The ALJ determined that she had several severe impairments, including cerebrovascular accident, degenerative disc and joint disease, ankle fracture, atrial tachycardia, obesity, hypertension, and peripheral neuropathy, but retained the residual functional capacity to perform the full range of sedentary work. The ALJ found she could perform past work as a billing clerk beginning March 29, 2022 and, alternatively, could perform other jobs in the national economy.
The Court’s Holding
Magistrate Judge Yvonne Y. Ho recommended denying A.C.’s summary-judgment motion, granting the Commissioner’s motion, and affirming the benefits denial. The court concluded that an ALJ need not adopt a particular medical opinion when setting residual functional capacity if the record otherwise contains substantial evidence supporting the assessment.
The court also rejected A.C.’s premise that the ALJ wholly rejected every medical opinion. The ALJ found certain state-agency opinions partly persuasive and accepted an examining doctor’s opinion about balance difficulties to the extent it supported a sedentary-work limitation. In any event, treatment notes and examination findings documenting generally mild-to-moderate strength and mobility limitations supplied substantial evidence for the sedentary RFC. A.C. also did not identify additional evidence that would likely have changed the outcome, so she failed to show prejudice from any alleged failure to further develop the record.
Key Takeaways
- An RFC need not mirror a specific medical opinion if substantial evidence in the record supports it.
- Finding medical opinions only partly persuasive is not the same as rejecting all medical-opinion evidence.
- A claimant alleging an undeveloped record must show prejudice by explaining what additional evidence could have changed the result.
Why It Matters
The recommendation applies Fifth Circuit precedent limiting challenges to an ALJ’s RFC determination based solely on the absence of a fully adopted medical opinion. It emphasizes that treatment records, examinations, and physicians’ observations can support an RFC assessment without the ALJ impermissibly substituting lay medical judgment.