11th Circuit Remand in Wheeler Reinforces SSR 96‑8p Requirements
- Jul 7, 2025
- 2 min read
⚖️ The Critical Issue in Wheeler
Omitted moderate limitations: Dr. Austin, a consulting psychologist, identified moderate restrictions in interacting with supervisors and coworkers.
ALJ’s RFC oversight: The Administrative Law Judge didn’t include these limitations in the residual functional capacity (RFC) determination.
No explanation given: SSR 96-8p requires an ALJ to explain why they diverge from medical source opinions—which was absent, resulting in reversal and remand.
💡 Key Takeaways for Practitioners
Include every medical limitation
Even moderate restrictions count.
A “moderate” limitation can materially affect a claimant’s ability to work.
Follow SSR 96-8p rigorously
Any discrepancy between RFC and medical opinions needs a clear ALJ justification.
Without this, decisions risk being vacated.
Ensure logical consistency
The RFC must be clearly rooted in the medical record.
Courts won’t re-weigh evidence but will look for a logical evidentiary chain.
👩⚖️ Questions & Answers
Q: What does "moderate limitation" mean in disability cases?
A: It’s more than minimal—it may significantly impact a person’s ability to perform work-related tasks, especially in social interactions or supervision.
Q: What does SSR 96-8p require when ALJ and medical opinions conflict?
A: If the ALJ’s RFC differs from a medical opinion, the ALJ must explain why that opinion was not adopted—otherwise, it’s reversible error.
Q: Will courts re-evaluate the evidence on appeal?
A: No, courts apply the substantial evidence standard. They check if the ALJ’s conclusion logically follows from the record—but do not re-weigh facts.
🧠 Why This Matters for Disability Advocates
Scrutinize ALJ decisions: Every omission, even small, can lead to remand.
Support strong RFC narratives: Document moderate limitations thoroughly and be ready to challenge ALJ rationales.
Reference pertinent SSRs: SSR 96-8p is foundational and non-negotiable.
🔗 Relevant Tower Law Group Resources
Want more on explaining RFCs? Check out our Key Lessons from Pahl v. Bisignano for guidance on ALJ-VE dialogue and RFC explanation.
See our Disability Decisions Archive for a full list of Circuit Court remands, including Wheeler and other recent precedents.
✅ Final Thoughts
Wheeler is a strong reminder: even “small” procedural errors like missing a moderate limitation can upend an ALJ’s decision. For advocates, it underlines the importance of rigorously checking RFCs, demanding full ALJ explanations, and citing critical SSRs like 96-8p in appeals.
Got any questions? Schedule a consultation with us. I’m here to help. It’s a lot to take in, but we’ll get through it together. After all, navigating these waters is always easier when you’ve got someone to chat with.
