Background
Christopher Bonham, a veteran with a history of spinal issues, applied for Social Security disability benefits covering the period from May 2012 to December 2016. He alleged severe impairments including degenerative disk disease and cervical spondylosis. An administrative law judge denied his claim, finding he retained the residual functional capacity to perform light work and his past relevant work as an airline security representative. The district court upheld the denial, and Bonham appealed to the Eighth Circuit.
The court’s reasoning
The court reviewed the administrative law judge’s decision under the substantial evidence standard. It rejected the argument that a residual functional capacity determination requires a specific medical opinion on workplace functionality. The court noted that regulations allow reliance on all relevant medical and other evidence, including clinical examinations and diagnostic imaging. The administrative record contained over 1,700 pages of medical records and numerous physical exams showing varying degrees of strength and mobility in Bonham’s left arm. The administrative law judge properly weighed conflicting evidence, including a VA physician’s associate opinion that Bonham could not use his left arm, against other exams showing strength between 3/5 and 5/5. The court found the administrative law judge’s conclusion that Bonham could perform light work was supported by this objective evidence.
The ALJ properly assessed Bonham’s residual functional capacity based on all of the relevant medical and other evidence.
The dissent
The record here does not allow the ALJ to determine what the medical evidence actually says about Bonham’s limitations.
Kelly
What it means going forward
The decision reinforces that administrative law judges are not required to obtain a specific medical opinion on functional capacity if the administrative record contains sufficient objective medical evidence to support a residual functional capacity determination.