Dwight Prude v. SSA: Defining Absenteeism and Mental Impairments in RFC Determinations

Introduction

Dwight Prude v. Commissioner of the Social Security Administration was decided by the Eleventh Circuit on December 13, 2024. Prude, a retired firefighter who also worked part-time as a high school sports referee, alleged that a combination of back, vision, sleep, headache, and mental health problems rendered him disabled as of January 2017. The Social Security Administration denied benefits at the administrative level. The district court affirmed, and Prude appealed, challenging (1) the Administrative Law Judge’s (ALJ’s) residual functional capacity (RFC) analysis for failure to account for absenteeism tied to medical appointments; (2) omission of mental‐impairment limitations from the RFC; (3) exclusion of vision‐related impairments; and (4) the overall finding that he could perform “light exertional work.” The Eleventh Circuit affirmed, holding that substantial evidence supported the ALJ’s findings and that no legal error was committed at any step of the five-step disability analysis.

Summary of the Judgment

The ALJ followed the five-step evaluation process under 20 C.F.R. § 404.1520, concluding at Step 2 that Prude’s lumbar spine disorder was “severe,” but his post-traumatic stress disorder (PTSD) was only “mild” and thus non-severe.
At Step 4, the ALJ assessed Prude’s RFC—including physical and mental abilities—relying on consulting physicians who found normal strength, range of motion, and intact conversational hearing and cognition.
The vocational expert testified that a hypothetical individual with Prude’s RFC could perform approximately 800,000 jobs in the national economy (e.g., fire assistant, cleaner, cashier).
Prude’s arguments on appeal—absenteeism, mental and vision limitations, and light-work capacity—were rejected as unsupported by the record. The Eleventh Circuit held that (a) mere appointment counts do not establish actual days off work; (b) the ALJ sufficiently considered non-severe mental limitations in the RFC; and (c) substantial evidence supported the physical and vision findings.
The court affirmed the district court’s judgment denying benefits.

Analysis

Precedents Cited

The Eleventh Circuit’s decision draws on long-standing precedent regarding substantial evidence review and the five-step SSA disability framework:

Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) – defining substantial evidence as “more than a scintilla” but “not high” and emphasizing deference to ALJ findings.
Raper v. Commissioner, 89 F.4th 1261 (11th Cir. 2024) – cautioning against needless repetition of factual analyses at multiple steps and reading the RFC determination in context.
Schink v. Commissioner, 935 F.3d 1245 (11th Cir. 2019) – holding that an ALJ must consider all impairments, severe or non-severe, in the RFC and cannot ignore uncontroverted medical opinions on mental limitations.
Biestek v. Berryhill, 587 U.S. 97 (2019) – clarifying that the substantial evidence threshold defers to the ALJ and does not require perfect logical flowcharts so long as the record as a whole supports the decision.

Legal Reasoning

1. Absenteeism and Medical Appointments: Prude argued that his seventy‐plus medical visits over 22 months equated to regular absences. The court held that appointment counts alone do not establish actual workplace absenteeism—especially where appointments were scheduled evenings and weekends and typically lasted under an hour. Absent record evidence that these visits overlapped with standard work hours or necessitated full-day absences, the ALJ reasonably excluded “absenteeism” from the RFC.

2. Mental Impairments in RFC: Under 20 C.F.R. § 404.1520a, an ALJ must identify “severe” impairments at Step 2 and then consider all impairments at Steps 4 and 5. Prude relied on Schink, where unaddressed bipolar limitations rendered an RFC defective. Here, however, the ALJ expressly noted in the RFC that Prude could “understand and remember,” “sustain concentration,” and “interact socially,” crediting non-examining consultants who found only mild PTSD restrictions. Read as a whole, the decision demonstrates adequate consideration of mental limitations.

3. Vision and Physical Capacity: Consultative examiners found Prude’s vision intact and normal strength and range of motion. The ALJ also considered Prude’s daily activities—yoga, sports refereeing, and animal care—to conclude he could do light work. Substantial evidence thus supports the conclusion that no vision‐related functional restrictions were required.

Impact

This decision reinforces several important principles in SSA disability jurisprudence:

Appointment frequency does not automatically translate into work‐preclusive absenteeism—claimants bear the burden of showing how medical visits translate into lost work time.
An RFC evaluation may rely on non-examining consultants and need not parrot the Step 2 “paragraph B” findings so long as it meaningfully incorporates all relevant mental and physical limitations.
Substantial evidence review remains deferential: the ALJ’s reasoning must be “logical and consistent” with the record, but need not be exhaustive in restating every prior finding.

Complex Concepts Simplified

Five-Step Framework: A sequential test—1) current work activity, 2) severity of impairment, 3) listed impairments, 4) residual functional capacity vs. past work, and 5) other work adjustment. Failure at any step ends the analysis.
Residual Functional Capacity (RFC): The most a claimant can still do despite impairments, measured in physical exertion (sedentary, light, medium, heavy) and mental/cognitive abilities (memory, concentration, social interaction).
Substantial Evidence: “More than a scintilla” of evidence that a reasonable person would accept as adequate to support the ALJ’s conclusion. Courts do not re-weigh the facts.
Non-severe vs. Severe Impairments: At Step 2, only “severe” impairments (those lasting ≥12 months and significantly limiting work) move forward. “Non-severe” impairments still must be considered in the RFC if they affect function.

Conclusion

Dwight Prude v. Commissioner clarifies that—absent concrete evidence linking medical appointments to workplace downtime—appointment tallies alone do not compel an ALJ to factor in “absenteeism.” It further confirms that an ALJ’s RFC need not replicate every Step 2 finding so long as mental and physical limitations are meaningfully integrated, supported by medical opinions, and consistent with the claimant’s activities. This decision thus strengthens SSA disability jurisprudence by reaffirming the deferential substantial evidence standard, delineating the burden of proof on claimants, and offering guidance on analyzing non-severe impairments in the RFC context.