A mental impairment can matter in a Social Security disability claim even when an administrative law judge labels it “non-severe.” The next question is whether the impairment causes specific limitations that belong in the residual functional capacity, or RFC. In Melody A. v. Commissioner of Social Security, decided October 16, 2026, a federal district court upheld an RFC without mental restrictions after finding that the ALJ had considered the claimant’s anxiety and explained the result.
What the claimant challenged
The claimant applied for Disability Insurance Benefits and alleged physical and mental conditions. The ALJ found severe physical impairments and a medically determinable anxiety impairment. Using Social Security’s special technique for mental impairments, the ALJ found no limitation in three broad functional areas and a mild limitation in interacting with others. He classified the anxiety as non-severe.
The ALJ assigned an RFC for a full range of sedentary work without mental restrictions and found the claimant could perform past semi-skilled work. In federal court, the claimant did not challenge the step-two non-severity finding. She argued that the ALJ had failed to account for anxiety in the RFC or adequately explain why no restriction was needed.
Consideration does not always mean a restriction
The court recognized that an ALJ must consider all medically determinable impairments when assessing RFC, including impairments found non-severe. But a finding of mild mental limitation does not automatically require an additional RFC restriction.
Here, the court found that the ALJ performed the more detailed RFC assessment. He discussed three opinions about mental functioning and compared them with the longitudinal records. He found one moderate limitation inconsistent with repeated examination findings, credited a no-to-mild assessment, and rejected an opinion of total inability to work when the claimed treatment relationship was not supported by the record.
The court therefore denied the claimant’s motion, granted the Commissioner’s motion, and affirmed the denial. It did not remand the case or award benefits.
Build the link between symptoms and work functions
The practical lesson is to document function, not only diagnosis. Evidence may address sustained concentration, pace, attendance, interaction, adaptation, or the ability to handle ordinary work stress. A medical opinion is more useful when it identifies the treatment relationship, supporting observations, expected duration, and why the limitation affects work throughout a normal schedule.
Normal findings at some visits do not necessarily describe functioning over an entire workday. If symptoms fluctuate, the record should explain their frequency, triggers, recovery time, and effect on reliable performance. Apparent inconsistencies should be addressed directly.
Melody A. is one district-court decision applying deferential substantial-evidence review. It does not establish that mild limitations never affect RFC or that an ALJ may ignore a non-severe impairment. The reasoning and the complete record remain important.
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