Summary
The United States District Court for the Middle District of North Carolina reviews the denial of Rosa Maria S.'s claims for Disability Insurance Benefits, Supplemental Security Income, and Disabled Widow's Benefits. The court rejects Plaintiff's argument that the Administrative Law Judge failed to perform a proper function-by-function evaluation of her ability to sit when formulating the residual functional capacity. The court concludes that the ALJ's decision is supported by substantial evidence and enters judgment for the Commissioner of Social Security.
Court
United States District Court for the Middle District of North Carolina
Jurisdiction
United States District Court for the Middle District of North Carolina
Decision date
March 24, 2026
Docket number
1:24CV1035
Disposition
dismissed
Questions Presented
- Whether the ALJ erred by failing to perform and explain a function-by-function evaluation of Plaintiff's ability to sit when formulating the residual functional capacity.
- Whether substantial evidence supported the ALJ's finding that Plaintiff could perform light work with the implicit sitting requirements of that exertional level.
- Whether the ALJ improperly considered objective medical evidence in evaluating the intensity, persistence, and limiting effects of Plaintiff's subjective pain symptoms.
Holdings
- The ALJ's failure to expressly assess Plaintiff's ability to sit on a function-by-function basis did not require remand because the decision supplied an accurate and logical bridge between the evidence and the finding that Plaintiff could perform light work, including its default sitting requirements.
- Substantial evidence supported the ALJ's finding that Plaintiff could perform light work with up to six hours of sitting in an eight-hour workday, generally in intervals of no more than two hours.
- The ALJ did not err by considering objective medical evidence along with Plaintiff's subjective reports and other evidence when evaluating the intensity, persistence, and limiting effects of her symptoms.
Court Document
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