Key Takeaways on Substantial Evidence and RFC

On October 12, 2023, the U.S. Court of Appeals for the Eighth Circuit affirmed the denial of disability insurance benefits in Wyatt v. Kijakazi, reinforcing important principles about how disability cases are reviewed—especially regarding substantial evidence and residual functional capacity (RFC) determinations.

📌 What the Court Held

✅ Substantial Evidence Is the Controlling Standard

• The court reaffirmed that decisions denying disability insurance benefits must be supported by substantial evidence in the record as a whole.

• “Substantial evidence” means more than a mere scintilla but less than a preponderance—enough evidence that a reasonable mind might accept it as adequate.

• This standard ensures that an adverse decision is well-founded and not arbitrary.

  
  

🧠 ALJ Is Responsible for RFC Determination

• The Administrative Law Judge (ALJ) is responsible for assessing the claimant’s residual functional capacity (RFC).

• RFC defines what an individual can still do despite their impairments, based on all relevant evidence.

  
  

📋 Medical Opinions vs. ALJ RFC Findings

• The court clarified that an ALJ is not required to adopt the exact limitations described in medical opinions—even those the ALJ finds persuasive.

• Instead, the ALJ must reasonably incorporate the effects of impairments into the RFC assessment.

• An RFC that differs from any single medical opinion can still be supported by substantial evidence so long as it aligns with the record as a whole.

  
  

👥 Interaction Limitations With Others

• In Wyatt, the ALJ declined to include more restrictive social-interaction limitations (e.g., interacting with coworkers and supervisors).

• The Eighth Circuit upheld this decision, finding no error.

• The court agreed that the ALJ’s RFC accurately reflected the evidence regarding the claimant’s ability to interact with others in the workplace.

  
  

📜 Standard of Review Confirmed

• The appellate court applied the traditional substantial evidence standard of review, declining to re-weigh evidence.

• Because the ALJ’s decision was supported by substantial evidence, the denial of disability benefits was affirmed.

  
  

🔍 Practical Takeaways for Practitioners

• ALJs have discretion in fashioning RFCs: they need not mirror any particular medical opinion verbatim.

• Consistency with evidence matters more than precise wording of limitations.

• Advocates should focus on building a robust evidentiary record, not just isolated medical opinions.

  
  

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.