Upholding ALJ’s RFC Determinations Under the Substantial Evidence Standard: Hicks v. Commissioner, SSA

Introduction

Hicks v. Commissioner, SSA, No. 24-10826 (5th Cir. Apr. 22, 2025), addresses the scope of appellate review in Social Security disability-insurance appeals, particularly the deference owed to an administrative law judge’s (ALJ’s) assessment of a claimant’s residual functional capacity (RFC). Plaintiff-Appellant Amy M. Hicks, a 67-year-old former dental assistant and vocational-school instructor, filed for Title II disability benefits alleging onset of disability on November 9, 2016. After denials at the agency level, an ALJ hearing, an adverse Appeals Council decision, and a district court affirmance, Hicks appealed pro se to the Fifth Circuit, challenging the ALJ’s RFC evaluation and ultimate disability determination.

Summary of the Judgment

The Fifth Circuit, in a per curiam opinion, affirmed the district court and the Commissioner’s denial of benefits. Applying the “exceedingly deferential” substantial evidence standard, the court concluded that (1) the ALJ properly followed the five-step sequential evaluation; (2) substantial evidence supported findings that Hicks had severe impairments but retained the capacity for modified light work through her last insured date; and (3) the ALJ correctly found Hicks capable of performing her past relevant work. The court declined to reweigh evidence or substitute its judgment for that of the ALJ.

Analysis

Precedents Cited

• Anthony v. Sullivan, 954 F.2d 289 (5th Cir. 1992): Established that a claimant must prove disability before the expiration of insured status under 42 U.S.C. § 423(a), (c).
• Masterson v. Barnhart, 309 F.3d 267 (5th Cir. 2002): Defined the disability standard as a medically determinable impairment lasting at least 12 months and preventing substantial gainful activity.
• Jason v. Heckler, 767 F.2d 82 (5th Cir. 1985): Provided the definition of residual functional capacity (RFC).
• Taylor v. Astrue, 706 F.3d 600 (5th Cir. 2012): Articulated the twofold appellate review standard—substantial evidence and proper legal standard.
• Leggett v. Chater, 67 F.3d 558 (5th Cir. 1995): Clarified that substantial evidence is “more than a scintilla” but need not be a preponderance.
• 20 C.F.R. §§ 404.1520c, 416.920c: Post-March 2017 regulations emphasizing supportability and consistency as primary factors in weighing medical opinion evidence.

Legal Reasoning

The court underscored the five-step sequential inquiry set out in 20 C.F.R. § 404.1520(a)(4): (1) substantial gainful activity; (2) severe impairment(s); (3) meeting or equaling a Listing; (4) ability to perform past relevant work given the RFC; and (5) ability to adjust to other work. Hicks reached step 4, where the ALJ found—on the basis of medical records, two state-agency consultants’ opinions, Hicks’s own symptom descriptions, and vocational expert testimony—that she could perform modified light work.

Applying the substantial evidence standard, the Fifth Circuit noted that the ALJ’s RFC assessment drew on a “record replete with medical documents” spanning years, and that the ALJ permissibly gave less weight to a conclusory letter from Hicks’s primary-care physician because it lacked temporal specificity and objective quantification. The court reiterated that it may not reweigh evidence or substitute its own judgment for that of the ALJ, even if arguable contrary evidence exists.

Impact

Hicks reinforces several enduring principles in Social Security disability jurisprudence:

• Deference to the ALJ’s RFC determinations so long as they are supported by substantial evidence.
• Strict adherence to the new 2017 opinion-evidence regulations, which prioritize supportability and consistency.
• The continuing importance of a robust administrative record, including objective medical evidence and well-reasoned agency opinions.
• Limitations on pro se litigants’ ability to challenge technical deficiencies in the ALJ’s reasoning without identifying specific regulatory or evidentiary errors.

Complex Concepts Simplified

• Substantial Evidence: Evidence that a reasonable mind might accept as adequate to support a conclusion. It requires more than a mere scintilla but less than a preponderance.
• Residual Functional Capacity (RFC): The most an individual can still do despite physical or mental limitations. It is expressed in terms of exertional levels (e.g., light work) and non-exertional abilities.
• Five-Step Sequential Evaluation: The mandatory procedure for determining disability under Title II, ending the inquiry as soon as a claimant is found disabled or not disabled at any step.
• Opinion-Evidence Rules (Post-March 2017): Regulations that require adjudicators to evaluate medical opinions based on supportability (how well the opinion is explained and supported) and consistency (how well it aligns with other evidence).
• Deferential Appellate Review: Courts may not reweigh evidence, substitute their judgment for the ALJ’s, or reverse unless no substantial evidence supports the decision or the ALJ applied the wrong legal standard.

Conclusion

Hicks v. Commissioner, SSA reaffirms that an ALJ’s carefully articulated RFC findings, grounded in a thorough review of medical records and agency opinions, will withstand appellate scrutiny under the substantial evidence standard. The case underscores the need for claimants—especially those proceeding pro se—to pinpoint specific regulatory misapplications or evidentiary deficiencies rather than broadly contest an adverse outcome. In the broader context, Hicks strengthens the legal principle that consistency and supportability govern the evaluation of medical opinions and that courts must defer to the ALJ’s reasoned analysis when substantial evidence buttresses the decision.