RFC Absenteeism Limits Need Evidentiary Support: Missed Appointments Alone Do Not Require a “Three Days per Month” Work-Absence Finding

I. Introduction

In Scott William Cartlidge v. Acting Commissioner of the Social Security Administration (11th Cir. Aug. 14, 2026) (unpublished, per curiam), the Eleventh Circuit affirmed the denial of disability insurance benefits and supplemental security income to a claimant alleging disability primarily due to bipolar disorder. The central dispute on appeal was narrow but common in mental-impairment cases: whether the administrative law judge (“ALJ”) erred in assessing residual functional capacity (“RFC”) by failing to include an absenteeism limitation—specifically, that the claimant would miss three workdays per month—based on the claimant’s testimony that he cancelled appointments about three days monthly.

The parties were Scott William Cartlidge (claimant/appellant) and the Acting Commissioner of the Social Security Administration (appellee). After two administrative hearings (the first resulting in a denial later vacated by the Appeals Council), the ALJ again denied benefits. The district court affirmed, and the Eleventh Circuit did as well.

II. Summary of the Opinion

The court held that substantial evidence supported the ALJ’s RFC determination limiting Cartlidge to medium work with significant mental-work restrictions (simple routine tasks, simple decisions, occasional interaction with others, and few routine changes). The Eleventh Circuit rejected Cartlidge’s argument that the ALJ was required to translate his testimony about cancelled medical appointments into a work-absence limitation. The court emphasized that the ALJ adequately explained why Cartlidge’s subjective statements about symptom intensity and functional impact were not fully consistent with the broader record.

The court also rejected Cartlidge’s reliance on Simon v. Commissioner, Social Security Administration, distinguishing it as a treating-opinion case rather than a subjective-symptom credibility/RFC case. Finally, the court noted that a nurse practitioner’s letter submitted to the Appeals Council—opining that maintaining employment would be “problematic”—did not warrant reversal, both because Cartlidge did not meaningfully challenge the Appeals Council’s denial of review and because statements that a claimant cannot work address an issue reserved to the Commissioner.

III. Analysis

A. Precedents Cited

1. Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005)

The opinion relies on Moore v. Barnhart for the governing standard of review: factual findings are reviewed for substantial evidence, while legal principles are reviewed de novo. The court also invokes Moore to reaffirm the appellate court’s limited role: it cannot reweigh evidence, make new credibility determinations, or decide facts anew. This framing is decisive here because Cartlidge’s argument effectively sought a reweighing of his testimony.

2. Barnes v. Sullivan, 932 F.2d 1356 (11th Cir. 1991)

Citing Barnes v. Sullivan, the court reiterates that even if the evidence might preponderate against the agency, the decision must be affirmed if supported by substantial evidence. This principle forecloses reversal where the claimant identifies an alternative inference (missed appointments → missed workdays) but the ALJ’s inference (testimony not fully consistent with the record) is adequately supported.

3. Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011)

Winschel v. Comm'r of Soc. Sec. is cited for the five-step sequential evaluation framework. While not the focus of the dispute, this citation underscores that disability is not decided by a single-factor logic test, but through a structured analysis culminating in RFC and vocational findings.

4. Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002)

Wilson v. Barnhart supplies the key doctrinal tool for resolving the claim: an ALJ may discredit subjective testimony if the ALJ articulates “explicit and adequate reasons” for doing so. The Eleventh Circuit concluded those reasons were articulated here (inconsistency with medical and other evidence, discussed at length in the ALJ’s decision).

5. Simon v. Commissioner, Social Security Administration, 7 F.4th 1094 (11th Cir. 2021)

Cartlidge argued that Simon required reversal because bipolar disorder can present with waxing-and-waning stability, and isolated “doing well” notations should not defeat disability evidence. The court distinguished Simon as involving an ALJ’s rejection of a treating provider’s opinion based on allegedly inconsistent treatment notes. Here, by contrast, the ALJ’s contested finding was a partial discounting of the claimant’s subjective testimony, not the improper rejection of a treating-source functional opinion. The opinion thus limits Simon to its context: it does not convert all bipolar-disorder cases into mandatory acceptance of subjective functional claims, nor does it impose a rule that appointment cancellations must equal work absences.

6. Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004)

The court uses Phillips v. Barnhart to reject Cartlidge’s attempt to reduce the disability inquiry to two propositions (no substantial gainful activity plus a severe impairment). Phillips is invoked to reinforce that ALJs must apply the full five-step framework, including RFC and the ability to perform past relevant work or other work.

B. Legal Reasoning

  1. Issue narrowed to RFC and subjective symptom evaluation. The court treated the absenteeism argument as an indirect challenge to the ALJ’s evaluation of Cartlidge’s subjective reports about symptom severity and functional impact. The opinion frames the proposed “three days per month” RFC limit as an extrapolation the ALJ was not required to adopt.
  2. Application of the “explicit and adequate reasons” requirement. Under Wilson v. Barnhart, the ALJ’s duty is not to accept subjective testimony, but to explain the weight given to it. The Eleventh Circuit found the ALJ satisfied this obligation by acknowledging the testimony and explaining that the alleged intensity/persistence/limiting effects were not entirely consistent with medical and other record evidence, which the ALJ reviewed in detail.
  3. Substantial-evidence deference controls the outcome. By invoking Moore v. Barnhart and Barnes v. Sullivan, the court positioned the appeal as a request to reweigh credibility and infer additional limitations. Because the ALJ’s reasoning had record support, the appellate court’s role was to affirm, not to select an alternative interpretation.
  4. Distinguishing treating-opinion errors from claimant-testimony disputes. The court’s treatment of Simon v. Commissioner, Social Security Administration draws a functional line: an ALJ’s improper discounting of a treating opinion based on “isolated entries” is different from an ALJ’s supported decision to only partially credit subjective symptom testimony. This distinction matters because it prevents Simon from being used as a general-purpose reversal tool whenever bipolar symptoms fluctuate.
  5. Appeals Council evidence and “reserved issue” statements. The court noted the claimant submitted a nurse practitioner’s letter stating he would continue to find maintaining employment “problematic.” The opinion observes (i) Cartlidge did not squarely challenge the Appeals Council’s “reasonable probability” determination, and (ii) in any event, statements about inability to work are reserved to the Commissioner under 20 C.F.R. §§ 404.1520b(c)(3)(i); 416.920b(c)(3)(i), meaning the agency is not required to analyze such statements as medical opinions establishing functional limits.

C. Impact

  • Absenteeism limitations must be supported, not assumed. The decision reinforces that an ALJ is not required to convert missed appointments or “bad days” testimony into a quantified work-absence RFC restriction unless the ALJ credits that inference and it is supported by the overall evidence.
  • Clarifies the reach of Simon in bipolar-disorder litigation. The opinion underscores that Simon is principally about improperly discounting treating-source opinions using selective “stable” notes, not about mandating acceptance of subjective reports or mandating specific RFC absenteeism findings.
  • Reaffirms deferential appellate review in SSA cases. By leaning heavily on substantial-evidence principles, the court signals that many RFC disputes—especially those turning on credibility and inference—will rise or fall at the ALJ level.
  • Practical consequence for claim development. Claimants seeking an absenteeism limitation should anticipate the need for concrete functional evidence (e.g., longitudinal treatment documentation, functional assessments, or well-supported opinion evidence) tying episodic symptoms to regular-and-continuing work incapacity, rather than relying on appointment patterns alone.

IV. Complex Concepts Simplified

  • Residual Functional Capacity (RFC): The most a person can still do in a work setting despite impairments, assessed on a “regular and continuing basis” (generally meaning 8 hours a day, 5 days a week).
  • Substantial evidence: Not “the best” evidence and not “more likely than not,” but enough relevant evidence that a reasonable person could agree with the ALJ’s conclusion.
  • Five-step sequential evaluation: A standardized process requiring the agency to assess work activity, severity, listings, RFC/past work, and other available work in the national economy.
  • Credibility / subjective symptom evaluation: The ALJ considers a claimant’s statements about symptoms but may discount them if the ALJ explains why they are inconsistent with other evidence.
  • “Reserved to the Commissioner” opinions: Statements like “the claimant cannot work” are legal conclusions assigned to the agency; medical sources can describe functional limitations, but the ultimate disability determination is not delegated to them.

V. Conclusion

The Eleventh Circuit’s decision affirms a practical rule in RFC adjudication: an ALJ is not required to incorporate a quantified absenteeism limitation based solely on a claimant’s testimony about episodic “bad days” or cancelled appointments, so long as the ALJ provides explicit, adequate reasons—grounded in the record— for not fully crediting that testimony. The opinion also confines Simon v. Commissioner, Social Security Administration to its treating-opinion context and reiterates that “cannot work” statements are reserved to the Commissioner. In the broader disability landscape, the case underscores that RFC disputes framed as inference and credibility challenges will rarely overcome substantial-evidence deference on appeal.