Clarifying Function-by-Function Analysis in RFC Determinations: Ward v. Dudek

1. Introduction

This commentary examines the unpublished Fourth Circuit decision in Donna Macklin Ward v. Leland C. Dudek, Commissioner of Social Security, No. 22-1555 (4th Cir. Apr. 29, 2025). At issue was the Social Security Administration’s denial of disability benefits to Ms. Ward, who suffered physical injuries and mental health exacerbations after a work-related accident in May 2016. The key questions on appeal were:

Whether the Administrative Law Judge (ALJ) adequately explained the residual functional capacity (RFC) findings on a function-by-function basis, as required by Social Security Ruling (SSR) 96-8p and Fourth Circuit precedent;
Whether the ALJ applied the correct legal standard in evaluating and discounting Ms. Ward’s subjective symptom testimony under 20 C.F.R. § 404.1529 and SSR 16-3p.

The Fourth Circuit, in an opinion by Chief Judge Diaz (joined by Judges Wynn and Keenan), affirmed the denial of benefits, finding that the ALJ applied the proper legal standards and that substantial evidence supported his factual findings.

2. Summary of the Judgment

The court’s decision can be distilled into three core holdings:

RFC Explanation and Function-by-Function Analysis: The ALJ properly identified Ms. Ward’s limitations, walked through her physical and mental impairments, and explained how the evidence supported a finding that she could perform light work with specific restrictions—without triggering a per se remand requirement for lack of an explicit function-by-function narrative.
Subjective Symptom Evaluation: The ALJ employed the two-step framework under 20 C.F.R. § 404.1529 and SSR 16-3p, first acknowledging that Ms. Ward’s impairments could produce her alleged symptoms and then assessing the intensity and persistence of those symptoms by comparing her testimony against other record evidence.
Substantial Evidence Standard: The court concluded that substantial evidence—a standard meaning “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion” (Biestek v. Berryhill, 587 U.S. 97 (2019))—underpinned the ALJ’s factual findings regarding both the RFC and the evaluation of subjective complaints.

3. Analysis

3.1 Precedents Cited

Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015): Established that an ALJ’s RFC assessment “must first identify the individual’s functional limitations or restrictions and assess his or her work-related abilities on a function-by-function basis.” The court here reaffirmed that while an explicit function-by-function recitation is not per se required, the decision must permit meaningful appellate review.
Biestek v. Berryhill, 587 U.S. 97 (2019): Defined “substantial evidence” as the relevant evidence a reasonable mind would accept, reinforcing the standard of review for ALJ factual findings.
Arakas v. Commissioner, 983 F.3d 83 (4th Cir. 2020): Laid out the two-step framework for evaluating subjective symptom testimony under 20 C.F.R. § 404.1529 and SSR 16-3p. The Fourth Circuit applied Arakas to confirm that the ALJ properly considered both the medically determinable impairments and the intensity/persistence of symptoms.
Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001): Emphasized that courts do not re-weigh evidence or substitute their judgment for that of the ALJ.
Patterson v. Commissioner, 846 F.3d 656 (4th Cir. 2017): Confirmed that an ALJ’s explanation must “show [the ALJ’s] work” so that appellate courts can meaningfully review whether the RFC conclusion is backed by evidence.

3.2 Legal Reasoning

The Fourth Circuit’s reasoning proceeded in two steps:

3.2.1 Function-by-Function RFC Assessment

— Under SSR 96-8p, the ALJ must identify functional limitations and assess them in terms of sitting, standing, walking, lifting, carrying, manipulations, postural functions, mental abilities, and environmental restrictions. While Mascio rejects any per se remand rule for the absence of an explicit, itemized RFC analysis, it requires that the written decision permit meaningful appellate scrutiny.

— The ALJ here did so by:

Listing each severe impairment—e.g., degenerative disc disease, shoulder tendinitis, knee meniscus tear, depression, anxiety;
Reviewing objective findings (imaging, range-of-motion tests, gait observations);
Discussing treatment records (injections, medications, therapy offers);
Explaining the weight accorded to state-agency consultants and treating physicians;
Describing the resulting limitations (e.g., light work, no ladders, occasional stooping or reaching, supervised uncoordinated interactions, no emergent situations).

3.2.2 Evaluation of Subjective Complaints

— Applying Arakas, the ALJ first acknowledged that Ms. Ward’s medically determinable impairments could produce her symptoms. He then compared her testimony about pain, fatigue, mood fluctuations, and daily activities to the rest of the record:

Noting her ability to cook simple meals, do light housework, shop bi-weekly, drive, pay bills;
Citing mental status exam results showing coherent thought processes, intact memory, cooperative demeanor;
Referencing medical evidence of relief from injections, normal gait, refusal of therapy;
Articulating why portions of her testimony were inconsistent with “the medical evidence and other evidence in the record.”

— The court held that the ALJ did not impose an impermissible “objective-evidence-only” test, but rather considered all record evidence—including daily-activity statements and third-party function reports—as required by SSR 16-3p.

3.3 Impact on Future Cases

This decision reinforces two important principles for Social Security disability adjudications in the Fourth Circuit:

ALJs retain flexibility in presenting RFC analyses. While they must “show their work,” they need not recite each function in an isolated subsection so long as the decision as a whole explains how the evidence supports each limitation.
Reviewing courts will uphold credibility assessments when the ALJ follows the Arakas two-step framework and points to inconsistencies between subjective statements and objective or other record evidence.

Practitioners should ensure that ALJ decisions clearly tie limitations back to particular pieces of evidence—medical tests, treatment records, daily activities—to survive appellate scrutiny without resorting to boilerplate or conclusory statements.

4. Complex Concepts Simplified

Residual Functional Capacity (RFC): A measure of the most a claimant can still do despite disabilities, covering physical (e.g., lift, stand, walk) and mental (e.g., concentration, social interaction) functions.
Function-by-Function Analysis: SSR 96-8p directs the ALJ to assess each work-related capability (sitting, lifting, handling, mental tasks) in turn, but Mascio allows flexibility so long as the decision shows how evidence supports each RFC finding.
Substantial Evidence: The evidence standard requiring enough relevant proof that a reasonable mind might accept; not the highest or preponderance standard.
Two-Step Subjective Symptom Evaluation: Under 20 C.F.R. § 404.1529 and SSR 16-3p, the ALJ first confirms a medically determinable impairment, then assesses whether symptoms’ intensity and persistence limit work capacity, weighing all record evidence.

5. Conclusion

The Fourth Circuit’s decision in Ward v. Dudek clarifies that:

An ALJ’s RFC assessment must permit meaningful review but need not rigidly itemize each function so long as the decision links limitations to record evidence.
The evaluation of subjective complaints must follow the Arakas two-step framework, considering both objective medical evidence and other record sources such as daily activities and third-party statements.
Substantial evidence review prohibits appellate courts from re-weighing evidence or second-guessing credibility determinations if the ALJ has applied the correct legal standards and explained the rationale.

Overall, Ward v. Dudek affirms the balance between thoroughness and flexibility in Social Security disability adjudications, providing guidance for ALJs and litigants on structuring RFC narratives and symptom analyses to withstand substantive appellate review.