Administrative-Social Security Disability-Denial of Benefits-Residual Functional Capacity Analysis

Plaintiff appealed the district court’s judgment upholding the denial of his application for Social Security disability benefits. Plaintiff was a military veteran who was diagnosed with cervical spondylosis and stenosis, which left him unable to use his left arm. Plaintiff applied and was approved for VA disability compensation and later filed a claim for Social Security disability. However, an ALJ concluded that plaintiff had residual functional capacity for light work. 

Where the ALJ’s RFC determination did not need to be based on a specific medical opinion, nor was there any categorical rule regarding functional evidence, there was sufficient evidence to support the ALJ’s findings regarding plaintiff’s remaining physical capabilities. 

Kelly, J., dissenting: “…the ALJ found that Bonham ‘was capable of . . . lifting, carrying, pushing, or pulling 20 pounds occasionally and 10 pounds frequently; standing and walking up to 6 hours in an eight-hour day and sitting up to 6 hours in an eight-hour workday[.]’ Because there is not sufficient evidence in the record to support these findings—and thus insufficient evidence to support the RFC—I respectfully dissent.”   

Judgment is affirmed. 

Bonham v. Bisignano (MLW No. 84858/Case No. 24-2999 – 21 pages) (U.S. Court of Appeals, 8th Circuit, Loken, J.) Appealed from U.S. District Court, Western District of Missouri, Bough, J. (Alexander Sutton Hall, Springfield, MO for appellant) (Edmund J. Rooney, SAUSA, Baltimore, MD for appellee; Molly Barry, SAUSA, Baltimore, MD on the brief)