Reaffirming the “Zone of Choice” in Social Security Cases: ALJ’s Global Record Statement Suffices for Combined-Impacts Review and Omission of Nonfunctional Lab Results Is Not Error

Introduction

This Sixth Circuit decision, authored by Judge Thapar and joined by Judges Moore and Ritz, concerns a challenge to the denial of Social Security disability benefits to Theresa A. DeMario. The Administrative Law Judge (ALJ) determined that, despite multiple impairments—neuropathy, carpal tunnel syndrome, headaches/migraines, obesity, and knee osteoarthritis—DeMario retained the residual functional capacity (RFC) to perform a limited range of light work with restrictions and could perform several jobs existing in the national economy. The district court affirmed; the Sixth Circuit now affirms as well.

The opinion addresses familiar but critical issues in Social Security disability appeals:

What the “substantial evidence” standard requires and how deferential it is to the agency (including the “zone of choice” doctrine).
Whether an ALJ must expressly analyze the combined effects of multiple impairments (including non-severe ones), or whether a global statement of having considered the entire record and “all symptoms” suffices.
Whether the ALJ errs by not discussing every piece of evidence, such as a lab test showing elevated inflammation, when the test lacks a demonstrated functional link to work limitations.
How daily activities, conservative treatment, improvement with interventions, and a lack of prescribed work restrictions can support a light-work RFC.

Summary of the Opinion

Applying de novo review to the district court’s judgment but giving deference to the agency’s fact-finding, the Sixth Circuit holds that substantial evidence supports the ALJ’s determination that DeMario is not disabled. The court emphasizes:

The “substantial evidence” threshold is “not high” and allows a “zone of choice” within which reasonable decisionmakers can decide either way without judicial interference.
The ALJ adequately considered the combined effects of all impairments—severe and non-severe—by expressly noting consideration of the entire record and “all symptoms,” and by tailoring RFC limitations to account for pain, balance issues, and environmental hazards.
The ALJ did not need to discuss every data point (e.g., a blood test suggesting generalized inflammation) absent a showing of its functional implications.
Evidence of daily activities, conservative treatment plans that provided relief, improvement with Botox injections, normal gait and strength findings, and the absence of medical work restrictions reasonably support an RFC for light work with limitations, including frequent (not constant) bilateral hand use.

The court rejects challenges premised on reweighing the evidence, reiterating that the presence of conflicting proof does not undermine an ALJ’s decision that is supported by substantial evidence. The judgment of the Western District of Kentucky is affirmed.

Analysis

Precedents Cited and Their Influence

Biestek v. Berryhill, 587 U.S. 97 (2019): The Supreme Court’s articulation of “substantial evidence” as “such relevant evidence as a reasonable mind might accept as adequate” is the centerpiece of the standard of review. The court reaffirms that this threshold “is not high,” reinforcing the deference due to the agency’s fact-finding.
Blakley v. Commissioner of Social Security, 581 F.3d 399 (6th Cir. 2009): Introduces the “zone of choice” concept—courts must not disturb an ALJ’s reasonable decision even where the record could support a contrary outcome.
Emard v. Commissioner of Social Security, 953 F.3d 844 (6th Cir. 2020): Supports the proposition that an ALJ’s explicit statement that she considered the entire record and “all symptoms” suffices to show that combined effects of impairments were evaluated. This directly answers the claimant’s argument that the ALJ failed to consider the interaction of obesity and knee pain.
Loral Defense Systems–Akron v. NLRB, 200 F.3d 436 (6th Cir. 1999): Although not an SSA case, it supplies a general administrative law principle: adjudicators need not discuss every piece of evidence to demonstrate that it was considered. The court uses it to reject the contention that the ALJ erred by failing to address an elevated inflammation lab test.
Ulman v. Commissioner of Social Security, 693 F.3d 709 (6th Cir. 2012), and Preston v. Commissioner of Social Security, 2023 WL 4080104 (6th Cir. June 20, 2023): These authorities underscore that courts do not reweigh the evidence on review; the mere existence of conflicting evidence does not unseat an ALJ’s decision supported by substantial evidence.
Hamilton v. Commissioner of Social Security, 98 F.4th 800 (6th Cir. 2024) (per curiam): Confirms the appellate posture—de novo review of the district court judgment with the agency’s findings binding if supported by substantial evidence.

Legal Reasoning

The court’s reasoning proceeds from the standard of review to a methodical application to each of the claimant’s arguments:

Substantial evidence and the zone of choice: The panel frames the inquiry under 42 U.S.C. § 405(g) and Biestek, emphasizing the low evidentiary threshold. The “zone of choice” permits affirmance so long as the ALJ’s reading of the record is reasonable.
RFC for light work with limitations: The ALJ recognized severe impairments (neuropathy, carpal tunnel syndrome, headaches) and deemed others non-severe (obesity, knee pain), but still incorporated limitations reflecting the entire constellation of symptoms—reduced lifting/carrying, sit/stand duration controls, environmental and hazard restrictions (e.g., no ladders, ropes, scaffolds; avoid unprotected heights and dangerous machinery).
Daily activities and conservative care as support: The ALJ relied on DeMario’s own testimony that she “can do most things,” though she pays for it later, and on documented capacity to run errands, perform personal care and simple household tasks. Conservative treatment (topical gels, braces, injections, medication) provided meaningful relief and was consistent with non-disability. Providers recommended exercise and did not impose work restrictions—factors reasonably supporting an RFC at the light-exertional level.
Combined-effects argument (obesity and knee osteoarthritis): Invoking Emard, the court holds that the ALJ’s repeated statements about considering the “entire record” and “all symptoms,” coupled with RFC limitations tailored to pain and endurance, suffice to show that combined effects were considered—even without a separate, point-by-point obesity analysis. The ALJ also referenced testimony about difficulty standing or walking for extended periods, reflecting functional consideration.
Undiscussed blood test (elevated inflammation): The court underscores that evidence must be tied to functional limitations. The test did not identify a cause, severity, or specific work-related impact, and adjudicators are not required to discuss every item of evidence. Thus, no reversible error.
Headaches and Botox efficacy: The claimant’s lifelong headaches did not preclude past substantial gainful activity (freelance writer; volunteer program manager), and Botox injections were documented to help. Even if there were conflicting entries about imperfect relief, substantial evidence supported the ALJ’s conclusion that headaches did not foreclose light work.
Neuropathy and balance: The treating observation that neuropathy “can” affect balance is generic and not a functional opinion about this claimant’s work capacity. Objective findings of normal gait, strength, and sensory status, along with exercise recommendations, undermined a claim of disabling imbalance. The ALJ nonetheless incorporated safety-related restrictions to account for balance concerns.
Carpal tunnel syndrome and hand use: Despite reported pain, DeMario exhibited full grip strength and range of motion; injections provided “good relief”; daily activities requiring manual dexterity remained feasible. On this record, concluding that she could use her hands “frequently” (as opposed to “constantly”) was comfortably within the ALJ’s zone of choice.

Impact and Practical Significance

While the opinion is “not recommended for publication” and therefore not precedential, it consolidates several recurring themes in Sixth Circuit Social Security practice:

The substantial evidence bar is low. Claimants face a meaningful uphill battle on appeal; if the ALJ cites reasonable record support, courts will not reweigh competing proof.
Combined-impairments review can be satisfied through an ALJ’s global statements and tailored RFC limitations. The Sixth Circuit continues to accept Emard’s approach rather than requiring granular, impairment-by-impairment crosswalks in every case.
Evidence without a functional bridge often carries little appellate traction. Lab tests or generalized medical observations must be tied to concrete work-related limitations (e.g., lifting, standing/walking tolerance, manipulative capacity, attendance/off-task) to matter on review.
Conservative treatment and daily activities remain probative. Where treatment is noninvasive, provides at least “fairly good benefit,” and providers do not impose restrictions, ALJs may rely on such evidence to support a light-work RFC, especially when daily activities show meaningful functioning.
Chronic conditions existing during prior work are relevant. If a claimant performed work with the same impairment (e.g., longstanding migraines) and the condition remains stable or improves, that history can weigh against a claim of new onset disability.

For practitioners, the decision underscores the value of:

Securing detailed functional opinions from treating sources that translate diagnoses and test results into explicit, work-related limitations.
Documenting the frequency, duration, and functional consequences of symptoms (e.g., headache logs consistent with SSR 19-4p), and the side effects of medication in vocational terms (off-task percentage, absenteeism).
Addressing “conservative care” narratives by explaining why more aggressive care was not pursued and how even conservative modalities leave clinically significant residual functional deficits.
Reconciling daily activities with asserted limitations, showing pacing, breaks, assistance, or post-activity recovery that distinguish household tasks from sustained work demands.

Complex Concepts Simplified

Substantial Evidence: A deferential standard. The question is not whether the court would have reached a different conclusion, but whether the ALJ’s conclusion is reasonably supported by “more than a scintilla” of evidence. If yes, the court affirms even if the record also supports a contrary view.
Zone of Choice: If the record can reasonably support either granting or denying benefits, courts do not substitute their judgment for the ALJ’s. The ALJ has discretion within that “zone.”
Residual Functional Capacity (RFC): The most a person can do in a work setting despite impairments. It is expressed in exertional terms (sedentary, light, medium, etc.) and includes postural, environmental, and manipulative limitations.
Light Work (generally): Typically involves lifting no more than 20 pounds occasionally and 10 pounds frequently, frequent standing/walking (about 6 hours in an 8-hour day), and may include some sitting. The precise RFC can further restrict climbing, hazards, or other conditions.
Severe vs. Non-Severe Impairments: “Severe” impairments significantly limit basic work activities. “Non-severe” do not. Importantly, ALJs must consider both severe and non-severe impairments in the RFC.
Frequent vs. Constant Hand Use: In vocational terms, “frequent” means occurring from one-third up to two-thirds of the workday; “constant” means two-thirds to all of the time. Allowing “frequent” but not “constant” use meaningfully limits jobs requiring near-continuous hand activity.
Conservative Treatment: Noninvasive, lower-intensity medical care (e.g., braces, topical gels, injections, oral meds). Improvement with such care can weigh against disability when it aligns with daily functioning and an absence of medical work restrictions.
Combined-Impacts Requirement: The agency must consider the aggregate effect of all impairments. In the Sixth Circuit, a documented global review of “all symptoms” and the “entire record,” combined with tailored RFC limitations, generally satisfies this obligation.

Conclusion

The Sixth Circuit’s affirmance in DeMario v. Commissioner of Social Security reinforces core principles of Social Security appellate review. Most notably, it reaffirms the deference inherent in the substantial-evidence standard and the “zone of choice,” clarifies that an ALJ’s expressed consideration of the entire record can satisfy the combined-impairments requirement, and confirms that an ALJ need not discuss every piece of evidence—particularly where the evidence lacks a demonstrated functional nexus to work limitations.

For claimants and practitioners, the case illustrates the importance of translating medical findings into specific, work-related functional restrictions, explaining treatment choices and symptom persistence notwithstanding conservative modalities, and contextualizing daily activities within the rigors of sustained employment. While unpublished and nonprecedential, the decision is a cogent, practical restatement of Sixth Circuit doctrine that will continue to influence district court adjudication and administrative litigation strategy in disability cases.