A Lesson in Explaining Residual Functional Capacity

We all know the importance of a well-reasoned residual functional capacity (RFC) determination. But what happens when an ALJ makes a conclusion without adequately explaining how they got there?

Enter Ginder v. Commissioner of Social Security (3d Cir. 2025). The Third Circuit vacated the district court’s decision affirming the denial of benefits because the ALJ failed to justify why Ginder could perform light work.

📌 The Case Breakdown

 Claim & Procedural History

Ginder applied for Social Security Disability Insurance (SSDI) in 2019, citing multiple conditions: back pain, diabetes, fibromyalgia, depression, anxiety, insomnia, asthma, and nerve damage in her hands.

Despite these impairments, the Agency denied her claim. She requested a hearing before an ALJ, who also found her not disabled. The Appeals Council denied review, and the district court upheld the ALJ’s decision.

On appeal to the Third Circuit, the key issue was whether the ALJ properly explained the decision to assign Ginder an RFC for light work.

The ALJ’s Findings & The ProblemThe ALJ acknowledged Ginder’s severe impairments, including:✔️ Diabetes✔️ Obesity✔️ Asthma & Allergic Rhinitis✔️ Right Carpal Tunnel Syndrome & Trigger Finger✔️ Lumbar Disc Disease

However, the ALJ concluded that despite these conditions, Ginder could perform "light work" with restrictions such as:

• Frequent reaching, handling, and fingering

• Occasional postural maneuvers

• Occasional exposure to temperature extremes, humidity, and respiratory irritants

• Work limited to simple and routine tasks

The Problem? The ALJ never fully explained why the evidence supported these limitations, especially given that light work requires standing or walking for the majority of an 8-hour workday (SSR 83-10).

“The ALJ did not identify evidence supporting a finding that Ginder could stand or walk for that amount of time.” (Ginder).

Ginder testified that her back pain prevented her from standing for more than 10 minutes at a time and that she could only walk for about a block before needing to sit. She also said she could only sit for about 30 minutes before needing to change positions.

The Third Circuit noted that the ALJ did not address this testimony, leading the court to state:

“We are unable to tell if it ‘was not credited or simply ignored.’” (Ginder, citing Burnett v. Comm’r of Soc. Sec. Admin., 220 F.3d 112, 121 (3d Cir. 2000)).

That’s a big issue. Courts want to see a logical bridge between the evidence and the conclusion. Here, that bridge was missing.

💡 Insights

An ALJ’s decision can’t just be a conclusory statement, it has to contain “a clear and satisfactory explication of the basis on which it rests” (Fargnoli v. Massanari, 247 F.3d 34, 41 (3d Cir. 2001)).

Ginder’s own description of her limitations should have been addressed, whether the ALJ chose to accept or reject them. Courts don’t like it when testimony is ignored.

The Third Circuit’s message was clear: If an ALJ is assigning a light work RFC, they must point to actual evidence supporting that standing/walking ability.

Final outcome? Vacated & Remanded

The Third Circuit sent the case back with instructions for the ALJ to:

• Reassess the RFC determination

• Explain how the evidence supports (or contradicts) Ginder’s ability to perform light work

• Address whether her testimony should be credited

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.