Background
Laharold Woodhouse applied for Disability Insurance Benefits in January two thousand twenty-three due to ailments affecting his neck, back, shoulders, knees, ankles, and feet, including severe migraines. The Social Security Administration denied his application after he exhausted administrative appeals, including a hearing before an administrative law judge who concluded he was not disabled under the Social Security Act. The district court affirmed the Commissioner’s decision, and Woodhouse appealed to the Eleventh Circuit.
The court’s reasoning
The court applied the substantial evidence standard to review the Commissioner’s decision. While the court agreed that the administrative law judge must discuss the limiting effects of severe impairments like migraines, it found the judge had done so by mentioning the condition over twenty times. The court noted that medical evidence, including the lack of medication refills and the claimant’s ability to perform daily activities, contradicted his claims of severe limitations. The court concluded the judge’s residual functional capacity assessment was supported by substantial evidence and that the claimant could not substitute his judgment for that of the agency.
The ALJ mentioned Woodhouse’s migraine headaches over twenty times throughout her thorough and well-reasoned decision.
Woodhouse v. Comm’r of Soc. Sec., No. 25-13593, slip op. at 5 (11th Cir. June 23, 2026)
What it means going forward
This decision reinforces that administrative law judges must explicitly address severe impairments in their residual functional capacity findings, but courts will not reverse if the record shows the impairment was considered and the conclusion is supported by substantial evidence.