Migraines can affect more than tolerance for bright light or noise. They also can interrupt a schedule, reduce time on task, and cause absences. In Katty D. v. Commissioner of Social Security, decided October 16, 2026, a New York federal court remanded because the administrative law judge did not adequately explain those possible effects.
A partially favorable decision left an earlier period in dispute
Katty D. applied for Disability Insurance Benefits with an alleged onset date in May 2020. The ALJ found her disabled beginning October 18, 2024, when her age category changed, but not disabled before that date. For the earlier period, the ALJ found that she could perform a reduced range of sedentary work.
The RFC restricted exposure to extreme bright lights, limited noise, and included other physical and mental limits. It did not include a schedule, attendance, or off-task restriction. That omission mattered because an examining doctor opined that migraines might interrupt Katty D.’s schedule.
The record supported the concern the ALJ rejected
The ALJ called the schedule-interruption opinion unsupported. The court found that explanation inadequate. The ALJ’s own discussion identified reports of daily headaches lasting three to four hours, nearly daily headaches, nausea, dizziness, double vision, photophobia, treatment, and multiple medications.
The Commissioner pointed to opinions finding no difficulty staying on task or maintaining attendance. The court explained that those opinions addressed mental impairments, not migraine headaches. The ALJ also had found one of those opinions unpersuasive and assessed greater concentration limits than state reviewers proposed.
The vocational expert testified that being off task 15 percent of the workday or absent three times each week would eliminate all jobs. Because those consequences could be work-preclusive, the court required a clearer explanation of whether the migraine evidence supported schedule interruptions and how the RFC accounted for nausea, dizziness, and light sensitivity.
Document the functional pattern of migraines
A useful migraine record describes frequency, duration, associated symptoms, triggers, treatment response, and recovery time. It also explains effects on sustained concentration, pace, predictable attendance, and the ability to remain on task between ordinary breaks. A medical opinion is stronger when its limitations are connected to those observations and the relevant treatment period.
This decision does not establish a required off-task percentage for migraines. It is a nonprecedential district-court opinion applying one record. The court ordered a sentence-four remand for further proceedings; it did not find Katty D. disabled during the disputed period or award benefits.
Source: Katty D. v. Commissioner of Social Security, 2026 U.S. Dist. LEXIS 236918 (S.D.N.Y. Oct. 16, 2026).
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