Eighth Circuit Clarifies Disability Claim Standards

Jan 26

2 min read

Two women in an office, one holding a pencil and tablet, engaged in discussion. Background features large window. Mood: focused.

In Welch v. Bisignano (Jan. 9, 2026), the Eighth Circuit Court of Appeals upheld the denial of disabled child’s insurance benefits and Supplemental Security Income (SSI). While the outcome isn’t surprising, the reasoning offers important reminders for disability advocates—especially regarding how diagnoses, impairments, and medical evidence are evaluated.

Diagnosis Alone Is Not a Medically Determinable Impairment (MDI)

Q: Does having a diagnosis guarantee a medically determinable impairment?A: No. In Welch, the ALJ found that fibromyalgia, autism spectrum disorder (ASD), and ADHD were not medically determinable impairments—even though they appeared in the record. The Court supported this conclusion, citing a long-standing principle: a diagnosis label alone isn't enough without evidence that the diagnostic criteria are met through longitudinal medical documentation.

Key Takeaways:

Courts expect the diagnostic criteria for fibromyalgia and neurodevelopmental disorders to be clearly documented, not just noted.
Even if some providers assign a diagnosis, the ALJ can reject it if it lacks objective or specialist confirmation.

“Non-Severe” Doesn’t Mean “Ignored” in RFC Analysis

The ALJ found the claimant’s migraines to be non-severe, but still considered related symptoms when crafting the Residual Functional Capacity (RFC). The Court approved of this approach, distinguishing between ignoring an impairment versus addressing its functional impact.

Q: Do step-two findings doom a claim?A: Not necessarily. As long as the ALJ evaluates the symptoms when determining RFC, courts are unlikely to reverse just because a condition was found “non-severe.”

Practice Tip: Unless you can prove the ALJ completely ignored a symptom, step-two appeals remain difficult.

Discounting Opinion Evidence: Internal Inconsistencies Matter

The ALJ gave limited weight to several sources:

A psychiatric nurse practitioner
A medical expert from a prior hearing
Lay witnesses (partner, grandmother, case worker)

The Court upheld all of these decisions, focusing on the internal inconsistencies and lack of support in the broader record.

Q: Will courts overrule ALJs on credibility findings?

A: Not likely—especially when ALJs provide clear explanations rooted in the medical record.

No DOT Conflict = No Extra Duty on the ALJ

The claimant argued there was a conflict between the vocational expert's testimony and the Dictionary of Occupational Titles (DOT). But the Court found no “apparent conflict,” which meant the ALJ wasn’t required to investigate further.

Reminder: If there's no obvious conflict, ALJs don’t have to probe. It’s up to claimants to raise specific, supported objections.

Final Thoughts: Diagnosis ≠ Outcome—Functional Evidence Still Reigns

Welch v. Bisignano is a strong example of the Eighth Circuit’s continued deference to ALJs who write detailed, well-supported decisions. The case reinforces key points:

Functional capacity is more important than diagnosis labels.
Courts defer to ALJs when decisions are consistent and tied to evidence.
MDI findings and RFC analysis remain core battlegrounds.\

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.