When Medical Findings Don’t Explain an Ability to Work
A diagnosis does not, by itself, establish disability. But medical test results do not necessarily establish an ability to work, either. In Griffin v. Bisignano, a Pennsylvania federal court examined the gap between evidence of serious impairments and the functional findings used to deny Social Security Disability Insurance benefits.
The court sent the claim back for further proceedings because the administrative law judge’s assessment of work capacity lacked substantial evidentiary support.
What was missing from the record?
The claimant applied for SSDI in 2023. The ALJ recognized severe impairments involving hypertension, cardiomyopathy, and vision, including blindness in the left eye. Nevertheless, the ALJ found that the claimant could perform medium work, subject to additional restrictions involving posture, vision, and workplace hazards. That finding supported a denial based on past work and alternative jobs.
The difficulty was the medical foundation for those restrictions. Both state-agency consultants had found insufficient evidence to assess the claimant’s residual functional capacity, or RFC—the most a person can do despite their limitations. Neither supplied specific work-related limitations, and neither had the most recent medical evidence.
Those insufficiency findings were not affirmative evidence that the claimant could meet medium-work demands. The ALJ nevertheless translated cardiac and eye findings into a work-capacity assessment without a medical functional opinion connecting those findings to the limitations selected.
Daily activities mattered, but did not resolve the gap
The record also contained evidence unfavorable to the claim. The ALJ cited independent living, household chores, public transportation, and fishing for as long as 12 hours.
Those activities were relevant to evaluating the claimant’s reported limitations. A persuasive appeal must address such evidence rather than ignore it. But the court still concluded that this record did not adequately support the RFC. The central problem remained the ALJ’s interpretation of medical findings without sufficient evidence explaining their functional significance.
What the decision does—and does not—mean
The ALJ ultimately decides RFC, and the claimant retains the burden of establishing disability. Griffin does not mean that every case requires a physician to provide an RFC matching the ALJ’s conclusions.
It does illustrate the ALJ’s responsibility to develop a full and fair record when the available evidence is inadequate, even when the claimant has counsel. The useful question is specific: What evidence explains how the claimant’s current medical condition affects the demands of sustained work?
For claimants reviewing a denial, a missing functional assessment can deserve close attention. The issue is not simply whether the file contains many medical records, but whether those records support the particular work abilities the ALJ found. Our discussion of an incomplete hearing record in Ball v. Bisignano examines another record problem that can affect federal review.
The court vacated the denial and remanded under sentence four of 42 U.S.C. § 405(g). It did not award benefits or find the claimant disabled.
Source: Griffin v. Bisignano, No. 1:25-cv-01677, 2026 WL 2905680 (M.D. Pa. Sept. 28, 2026).
If you are considering a federal appeal of an SSDI denial, you may schedule a consultation with Feden Law Group to discuss your decision and record.
This article provides general information, not legal advice, and does not create an attorney-client relationship.