Christopher Brad Bonham v. Frank Bisignano, Commissioner of Social Security

United States Court of Appeals
For the Eighth Circuit
___________________________
No. 24-2999
___________________________
Christopher Brad Bonham
lllllllllllllllllllllPlaintiff - Appellant
v.
Frank Bisignano, Commissioner of Social Security
lllllllllllllllllllllDefendant - Appellee
____________
Appeal from United States District Court
for the Western District of Missouri
____________
Submitted: September 16, 2025
Filed: June 2, 2026
____________
Before LOKEN, KELLY, and ERICKSON, Circuit Judges.
____________
LOKEN, Circuit Judge.
Christopher Bonham is a veteran with a long history of neck and back
problems. In May 2012, following his military service, these problems worsened, and
he complained to his primary medical care provider at the Department of Veterans
Affairs (VA). Medical imaging in July showed cervical spondylosis with a herniated

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disk at C6-C7, causing neural foraminal stenosis.1 A neurosurgeon performed a
comprehensive exam. Based on the medical imaging and severe pain Bonham was
experiencing, the neurosurgeon decided surgery was appropriate. Bonham had C6-
C7 spinal fusion surgery in October. In 2016, after repeated trips to the emergency
room and to various doctors for treatment, Bonham underwent a VA Compensation
and Pension physical examination performed by Jon Keller, a physician’s associate
(PA), who concluded Bonham was unable to use his left arm.2 The VA granted him
limited disability benefits.
I.
After relying on VA benefits for five years, Bonham applied to the Social
Security Administration (SSA) for Social Security disability benefits in 2021, alleging
a disability onset date of May 12, 2012. As his insured status expired in 2016, he was
eligible for SSA disability benefits from May 12, 2012 to December 31, 2016. He
continued to receive VA benefits.
Bonham’s disability application alleged several severe impairments, including
degenerative disk disease, cervical spondylosis, left ankle pain, hypertension, sinus
problems, unspecified depressive disorder and alcohol abuse. In July 2022, SSA
1Foraminal stenosis occurs when the spinal cord narrows and causes
compression of the spinal nerves. Cleveland Clinic, Foraminal Stenosis,
https://my.clevelandclinic.org/health/diseases/24856-foraminal-stenosis.
2PAs generally undergo three years of further education after obtaining their
undergraduate degree, with no residency requirement. Am. Acad. of Physician’s
Associates: Career Central, Become a PA https://www.aapa.org/career-central/
become-a-pa/. Physicians attend four years of schooling after graduating college and
three to seven years of residency and fellowship training. Ass’n of Am. Med. Colls.:
Aspiring Docs, MD and DO Programs, https://students-residents.aamc.org/media/
9971/download.
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Administrative Law Judge Jan E. Dutton (the ALJ) conducted an informal
administrative hearing at which Bonham and a vocational expert (VE) testified.
Bonham’s testimony in support of his claim detailed the effects of his impairments
during the period for which he is seeking SSA disability benefits, May 12, 2012 to
December 31, 2016 -- that he was unable to use his left arm, as he told PA Keller in
2016; is almost bedridden; cannot bend down; and could only lift one two-liter bottle
of soda in his left arm. Bonham presented no medical opinion evidence regarding his
ability to perform work. Regarding the lack of medical opinion evidence, his attorney
stated that Bonham’s VA primary care doctor was asked to provide a medical opinion
but responded, “he does not do those for VA.” Counsel told the ALJ, and Bonham
confirmed, that his VA disability benefits rating had increased to 80% in 2022.
Counsel said, “I would not object . . . if you sent us out to an ME [medical
examiner] . . . it’s very possible he might meet or equal a listing for his neck.” Cf.
20 C.F.R. § 404.1519a(b). The ALJ did not do so.
The extensive administrative record includes 1745 pages of Bonham’s
Outpatient Hospital records from September 2011 to December 2016, 19 pages of
Emergency Department Records from October 2012 to May 2014, and two pages of
a SSA Recent Medical Treatment form stating that Bonham had surgery in 2022 to
replace disks C4-5 and will need another surgery to replace disk C3. Two SSA
consulting doctors looked at Bonham’s records and found there to be insufficient
evidence to render an opinion about his functional abilities.
After the hearing, the ALJ issued a lengthy opinion denying the benefits
application, applying the well-established five-step evaluation process set forth in the
SSA regulations. See 20 C.F.R. § 404.1520(a)(4). At step one, the ALJ found that
Bonham had not engaged in substantial gainful activity during the relevant period,
a key element of a disability claim. In steps two and three, the ALJ concluded that
Bonham had severe impairments -- “degenerative disk disease and spondylosis of the
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cervical spine with history of C6-7 fusion in 2012 and lumbar radiculopathy” -- but
they are not listed impairments, so he was not disabled at step three. See 20 C.F.R.
§ 404.1520(d).
Steps four and five ask whether the claimant can still do his or her past relevant
work and if not, whether “you can make an adjustment to other work.” These steps
each require an assessment of the claimant’s residual functional capacity (RFC), see
§ 404.1520(a)(4)(iv)-(v), defined as “the most you can still do” in a “work setting . . .
despite your limitations,” 20 C.F.R. § 404.1545(a)(1); see Hensley v. Colvin,
829 F.3d 926, 931-34 (8th Cir. 2016). The ALJ found: “[b]ased on the totality of the
evidence . . . the claimant was capable of performing a range of light work (i.e.,
lifting, carrying, pushing, or pulling 20 pounds occasionally and 10 pounds
frequently; standing and walking up to 6 hours in an eight-hour day and sitting up to
6 hours in an eight-hour workday).” However, the ALJ “limited the claimant to
frequent [rather than constant] handling, fingering, and feeling and [only] occasional
overhead reaching” and “avoiding concentrated exposure to hazards, secondary to
chronic pain.”
The VE testified that Bonham’s past relevant work as an airline security
representative, as generally performed, is defined as light work in the Dictionary of
Occupational Titles. If Bonham had the RFC to perform the full range of light work,
the SSA Medical-Vocational Rules would direct a finding of not disabled at step 4.
See 20 C.F.R. Pt. 404, Subpt. P, App. 2, §§ 202.13, 202.20. But Bonham described
the work as he performed it as “heavy” or “very heavy” work because he lifted around
100 pounds constantly. Comparing Bonham’s RFC “with the physical and mental
demands of this work,” the ALJ found he was able to perform his past relevant work
as an airline security representative as it is generally performed and found he was not
disabled at step four.
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Turning to step five, the ALJ found that Bonham’s ability to adjust to the
demands of other work was impeded by exertional and nonexertional limitations that
“erode the unskilled light occupational base.” Accordingly, in posing an available
work hypothetical to the VE, the ALJ modified the RFC to be considered:
Q Specifically . . . this is an individual who could lift 20 pounds
occasionally, ten pounds frequently, who could stand, sit, or walk for at
least six hours in an eight-hour day. I’m going to say could use his arms
for frequent not constant handling, fingering, and feeling and could do
occasional overhead reaching. And should avoid concentrated exposure
to vibration or hazards that would be heights or dangerous machinery or
equipment. With that functional capacity, could such an individual
return to the airline security job?
A This hypothetical person could work as an airline security
representative as generally but not actually performed.
Q And how many of those [actually performed] jobs exist in the
nation?
* * * * *
A 38,300, Judge.
Q In addition, would there be other work and if so, could you
give three examples of other work at step five?
A . . . This person could also work as a sample distributor. . . .
There are 33,800 [jobs] in the national economy. This person could also
work as a housekeeping cleaner. . . . There are 219,700 in the national
economy. This person could also work as a ticket taker. . . . There are
133,900 in the national economy.
Q . . . Is there any light factory or manufacturing work that would
meet this hypothetical?
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* * * * *
A The person could also work as a subassembler . . . light
exertion. . . . There are 17,200 in the national economy.
The ALJ credited the VE’s testimony; found that, despite his severe impairments,
Bonham was not disabled at steps four and five; and denied his SSA disability
benefits claim. Regarding PA Keller’s “opinion evidence,”3 the ALJ noted:
The claimant underwent a compensation and pension evaluation in May
2016, which concluded that he is unable to use his left upper extremity
due to muscle weakness. However, while the conclusion is supported
by the findings of muscle atrophy with 0/5 muscle strength in the left
elbow during that particular exam, it is not consistent with other exams
during the relevant period, which showed between 3 and 5/5 muscle
strength in the left upper extremity. Therefore, this opinion is not
persuasive because it is not consistent with the other substantial
evidence of record. (Record citations omitted.)
II.
After the SSA Appeals Council denied further review, Bonham sought judicial
review of the adverse final decision in the Western District of Missouri, arguing that
remand to the agency is necessary because the record contains only one medical
opinion -- P.A. Keller’s exam -- that described Bonham’s ability to function in a
workplace. When the ALJ rejected that opinion, she did not sufficiently develop the
3Licensed PAs are now an “acceptable medical source” under the revised SSA
disability regulations. See 20 C.F.R. § 404.1502(a)(8). Under the regulations in
effect when Keller examined Bonham in 2016, their opinions could be considered but
were not an acceptable medical source.
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record and base her RFC determination on substantial evidence. The district court4
upheld the denial of benefits:
I understand the difficulty of this determination given the timeframe
[Bonham’s decision to wait five years before seeking SSA disability
benefits], but the ALJ did the best they could and analyzed that medical
finding and the functioning finding and compared and contrasted it with
the other functioning findings that were in the record and documented
those, and then found that the one medical opinion stemming from the
zero-to-five muscle strength in the left elbow was not persuasive and
consistent with the substantial evidence on the record as a whole for that
timeframe. And so I’ll affirm the decision on that basis.
Bonham appeals the district court’s decision. We review de novo a district
court’s decision affirming the denial of benefits. Cropper v. Dudek, 136 F.4th 809,
813 (8th Cir. 2025). We affirm if the “ALJ made no legal error and the ALJ’s
decision is supported by substantial evidence on the record as a whole.” Kraus v.
Saul, 988 F.3d 1019, 1024 (8th Cir. 2021) (quotation omitted). “Under the
substantial-evidence standard, a court looks to an existing administrative record and
asks whether it contains sufficient evidence to support the agency’s factual
determinations.” Biestek v. Berryhill, 587 U.S. 97, 102 (2019) (cleaned up).
Substantial evidence “is less than a preponderance, but enough that a reasonable mind
might accept as adequate to support a conclusion.” Phillips v. Astrue, 671 F.3d 699,
702 (8th Cir. 2012) (quotation omitted). “[W]e will disturb the [ALJ’s] decision only
if it falls outside the available zone of choice.” Austin v. Kijakazi, 52 F.4th 723, 728
(8th Cir. 2022) (quotation omitted). We do not reweigh the evidence. Schmitt v.
Kijakazi, 27 F.4th 1353, 1361 (8th Cir. 2022) (citation omitted).
4The Honorable Stephen R. Bough, United States District Judge for the
Western District of Missouri.
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III.
The ALJ denied Bonham’s SSA disability claim at steps four and five of the
SSA’s sequential evaluation process because he has the RFC to perform his past
relevant work as generally performed (step four) and to make an adjustment to other
available work in the economy (step five).
In the “Statement of the Issues” section of his principal Brief, Bonham states
that the issue on appeal is:
Whether the ALJ violated the duty to develop the record and created an RFC
that lacked the support of substantial evidence after rejecting the only medical
opinion of record and without identifying evidence that illuminated Bonham’s
day-to-day ability to function in the workplace.
We agree with the government that “[t]he general issue presented is whether
substantial evidence supports the Commissioner’s final decision finding Bonham was
not disabled.” But we will address Bonham’s attempts to avoid this deferential
standard of review by arguing the ALJ committed purported errors of law.
A. Bonham argues that remand is necessary because the ALJ rejected PA
Keller’s medical assessment, the only medical opinion in the record that spoke to the
claimant’s ability to function in the workplace. By basing her decision on non-
functional medical reports and clinical findings that did not assess his functional
ability, Bonham argues, the ALJ relied on impermissible inferences about Bonham’s
ability to work and therefore violated her duty to develop the record and render an
RFC determination that is supported by substantial evidence. It is certainly true that
an ALJ does not have unfettered discretion to determine a claimant’s RFC. Social
security disability proceedings are non-adversarial, and the ALJ is responsible for
developing the record fairly and fully. Cox v. Astrue, 495 F.3d 614, 618 (8th Cir.
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2007). Therefore, the ALJ cannot render an opinion if a “crucial issue [is]
undeveloped,” but the ALJ has no duty to seek clarification of medical opinions if the
record contains other detailed clinical evidence of the claimant’s limitations. Stormo
v. Barnhart, 377 F.3d 801, 806 (8th Cir. 2004).
Bonham’s contention is fundamentally contrary to the controlling SSA
regulations. In 2017, after prolonged notice and comment rulemaking proceedings,
the agency adopted Revisions to Rules Regarding the Evaluation of Medical
Evidence. 82 FR 5844-01 (Jan. 18, 2017) (final rules). The revisions apply to
disability claims filed after March 27, 2017, such as Bonham’s. But one rule relating
to evaluating medical evidence did not change. Like the prior regulation, which still
applies to claims filed before that date, § 404.1545(a)(3) of the revised regulations
continues to define the “[e]vidence we use to assess your residual function capacity”:
We will assess your residual functional capacity based on all of the
relevant medical and other evidence. . . . We will consider any
statements about what you can still do that have been provided by
medical sources, whether or not they are based on formal medical
examinations. (See § 404.1513.) We will also consider descriptions and
observations of your limitations from your impairment(s), including
limitations that result from your symptoms, such as pain, provided by
you, your family, neighbors, friends, or other persons.
Controlling Eighth Circuit precedents apply this standard. “The Commissioner
must determine a claimant’s RFC based on all of the relevant evidence, including the
medical records, observations of treating physicians and others, and an individual’s
own description of [his] limitations.” Myers v. Colvin, 721 F.3d 521, 527 (8th Cir.
2013) (quotation omitted). “Because a claimant’s RFC is a medical question, an
ALJ’s assessment of it must be supported by some medical evidence of the claimant’s
ability to function in the workplace. However, there is no requirement that an RFC
finding be supported by a specific medical opinion.” Hensley, 829 F.3d at 932
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(cleaned up). For example, in Hensley, the ALJ determined the claimant’s RFC by
evaluating the relevant treatment records and the treating physician’s “To Whom It
May Concern” letter that detailed the claimant’s pain, strength, and gait. We upheld
the RFC determination notwithstanding the absence of a direct, “functional” medical
opinion, deeming the “medical record adequately developed.” Id. at 930-32.
Bonham argues that an RFC determination may not be based on inferences
drawn from “objective medical data (e.g., clinical examinations, diagnostic
imaging).” There must be “medical evidence,” which he defines as a “medical
professional’s opinion,” such as PA Keller’s, “regarding Bonham’s ability to function
in the workplace” -- what he calls “functional evidence.” This argument is directly
contrary to § 404.1545(a)(3) and has no direct support in the cases he cites. The
notion that there is no “functional evidence” in Bonham’s extensive medical records
is ludicrous. For example, during PA Keller’s examination, Bonham claimed that he
was not able to walk or stand, a claim he repeated at the hearing; Keller rejected this
claim because Bonham did both at the evaluation. Consistent with § 404.1545(a)(3),
the ALJ properly “assess[ed Bonham’s] residual functional capacity based on all of
the relevant medical and other evidence.”
Bonham contends that two cases establish our “long-held position” that an RFC
determination must be based on what he calls “functional medical evidence” --
Noerper v. Saul, 964 F.3d 738 (8th Cir. 2020), and Lauer v. Apfel, 245 F.3d 700 (8th
Cir. 2001). Neither case stands for this categorical proposition. In Noerper, a divided
panel reversed the district court and remanded the Commissioner’s denial of disability
benefits for further factual development. 964 F.3d at 746-47. We concluded the
mixed administrative record provided “simply no reliable evidence” supporting the
ALJ’s RFC determination that the claimant could stand or walk for six hours a day.
A consulting physician’s report that may have supported the RFC determination
predated other records that told a starkly different story about the claimant’s ability
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to walk or stand. This decision dealt with the complete lack of supporting evidence,
rather than the lack of a specific type of evidence. Id. The panel majority expressly
disclaimed that it was creating a categorical rule: “[W]e do not suggest that an ALJ
must in all instances obtain from medical professionals a functional description that
wholly connects the dots between the severity of pain and the precise limits on a
claimant’s functionality. Something, however, is needed.” Id. at 746. Section
404.1545(a)(3) and our earlier cases such as Hensley make clear that the “something”
may be based on reliable objective medical data such as clinical examinations and
diagnostic imaging and need not include a medical professional’s opinion regarding
the claimant’s functionality.
Likewise, in Lauer, again a split panel decision, we reversed not because of the
absence of functional evidence, but because the panel majority “located no medical
evidence” at all to support the ALJ’s RFC determination that the claimant’s mental
impairments limited only the degree to which he could interact with the public.
245 F.3d at 704. Ignoring medical assessments in the record, the ALJ noted that a
neutral medical advisor “concurred” in the ALJ’s RFC. But this medical advisor was
an internal medicine specialist, not a neurologist; had never assessed the claimant’s
mental impairments; and admitted at the hearing that a full conclusion about the
claimant’s RFC was impossible without future tests the advisor never subsequently
reviewed. Id. at 703-06. Again, not a categorical decision that an ALJ’s RFC
determination must be based on functional medical evidence rather than “objective
medical data” from which an RFC can be inferred.
Properly understood, Noerper and Lauer reiterate our actual “long-held”
position that an RFC must be based on some reliable medical evidence about the
claimant’s ability to function in the workplace, not that the evidence must be
functional in-and-of-itself. Read in conjunction, these fact-intensive precedents
establish no categorical rule regarding functional evidence.
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B. Bonham further argues that the ALJ’s RFC determination was not
supported by substantial evidence because it was based on inferences impermissibly
drawn from the objective medical reports, failed to identify some medical evidence
of Bonham’s ability to function in the workplace, and ignored medical evidence in
the record supporting Bonham’s reported limitations. Now we are into issues clearly
governed by the substantial evidence standard of review in which we ask whether the
administrative record contains sufficient evidence to support the ALJ’s factual
determination, disturbing the ALJ’s decision only if it “falls outside the available
zone of choice.” Hensley, 829 F.3d at 932. On this issue, Bonham bears the ultimate
burden of persuasion. Austin, 52 F.4th at 728.
The ALJ’s lengthy opinion focused in great detail on the voluminous hospital
medical records reflecting Bonham’s condition and medical treatment during the
disability period at issue. As this is a close case, we will summarize this extensive
medical evidence in some detail:
After the C6-7 surgery in October 2012, Bonham’s pain improved and his
strength remained mostly strong. On December 15, 2012, he had equal grip strength
bilaterally and good range of motion in his shoulders, with a limited ability to rotate
his head to the right. In a January 24, 2013 visit, Bonham displayed full range of
motion in all extremities and shoulders and equal strength bilaterally, with a slight
decrease (4/5) in his left grip strength. One week later, Bonham returned to the
doctor displaying significant weakness in his left triceps, but he acknowledged the
surgery relieved his pain.
About six months after the surgery, Bonham claimed that his pain returned.
The first post-surgery MRI in February 2013 displayed severe left neural foraminal
stenosis at C6-C7 and spinal canal stenosis at C4-C5 and C5-C6. In August 2013, an
MRI again showed severe neural foraminal narrowing at C5-C6 and C6-C7 but stable
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fusion and unchanged degenerative findings. In August 2014, an X-ray showed the
prior fusion “look[ed] good.”
Bonham received little to no regular treatment for his arm or neck from mid-
2013 to 2015, often missing his neurosurgery appointments. He repeatedly went to
the ER and other doctors for pain and pain medication. At these visits, the doctors
conducted various tests that revealed consistent, if slightly varied or diminished,
strength and mobility in his left arm. The relevant findings were:
• May 18, 2013: bilateral upper extremities had full motor strength.
The doctor noted Bonham displayed no weakness in his bilateral
upper extremities but reported chronic numbness in his left hand
and “uncontrolled” pain. He displayed no limp.
• June 11, 2013: full range of motion in Bonham’s neck but
decreased grip strength in his left arm. Due to pain, he was issued
a “TENS” unit shortly thereafter.
• February 21, 2014: equal 5+/5+ strength in all extremities; no
gross motor deficits.
• April 30, 2014: tested at a 5/5 in upper extremities; another report
noted “slight” weakness in his upper left extremity; inspection of
lower extremities “normal.” Pain level at 9 out of 10.
• May 15, 2014: 5/5 strength in all extremities; no sensory/motor
deficits; good range of motion in his arms; neck range of motion
limited.
• July 8, 2015: Bonham claimed 50% paralysis in his left arm.
Exam results were 3/5 strength in left arm; good range of motion
in all extremities but his neck; normal gait.
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• July 14, 2015: while undergoing alcohol detox, returned to ER six
days after his previous visit and three days after he voluntarily left
against medical advice. Same results as the July 8 examination.
• August 10, 2015: “chronic weakness” of left arm; and could shrug
his shoulders “some.” Limited range of motion in his neck; slight
weakness in left leg (4/5); normal knee flexion and extension;
pain level at 4.
• August 14, 2015: full 5/5 strength in both his upper and lower
extremities; normal muscle tone.
• October 15, 2015: 4/5 muscle strength in left elbow flexion,
shoulder abduction, grip strength, left hip flexion, knee
flexion/extension, and ankle dorsal flexion. Muscle atrophy in
his left arm and limited range of motion in his neck. Pain level at
9/10.
The ALJ concluded, after a thorough and systematic review of these medical
records and other evidence in the administrative record, that Bonham was not
disabled. As required, the ALJ based her decision on ample medical evidence about
Bonham’s ability to function in the workplace. See Hensley, 829 F.3d at 932. The
ALJ discussed Bonham’s scans, finding that some support his complaints of pain and
weakness but others showed stable degeneration. The ALJ discussed physical exams
and tests during the relevant period, finding that -- unlike some scans -- they “often
showed 5/5 motor strength and normal muscle groups and good range of motion in
all limbs.” The ALJ found that Bonham had the ability to use his left arm and was
capable of performing a range of light work in the workplace. She recognized the
objective medical and other evidence supporting Bonham’s alleged chronic pain and
symptoms, but concluded the record as a whole did not support the degree and
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severity he alleged.5 She accounted for this evidence of reduced strength, upper
extremity mobility, and pain by determining an RFC in the range of light work --
“lifting, carrying, pushing, or pulling 20 pounds occasionally and 10 pounds
frequently; standing and walking up to 6 hours in an eight-hour day and sitting up to
6 hours in an eight-hour workday” -- and then limiting Bonham “to frequent handling,
fingering, and feeling and occasional overhead reaching” and “avoiding concentrated
exposure to hazards, secondary to chronic pain.”
This was not a determination lacking “some medical evidence of the claimant’s
ability to function in the workplace.” Cox, 495 F.3d at 619. It was a determination
based on, and supported by, relevant objective medical reports, tests, and statements
by medical sources that § 404.1545(a)(3) directs an ALJ to consider.
The ALJ also acknowledged that PA Keller reached a different conclusion
regarding Bonham’s ability to use his left arm in conducting his VA exam in 2016.
She found this evidence unpersuasive because of its lack of consistency with other
findings in the record: “[w]hile the conclusion is supported by the findings of muscle
atrophy with 0/5 muscle strength in the left elbow during the particular exam, it is not
consistent with other exams during the relevant period, which showed between 3 and
5/5 muscle strength in the left upper extremity . . . .”
5Though Bonham claimed he was nearly bedridden, the ALJ found that medical
“exams . . . demonstrated a normal gait, with no mention or indication that the
claimant required the use of any assistive device.” Regarding use of his left arm, the
ALJ found that “physical examinations were not entirely consistent with the severity
and degree of limitation the claimant alleges.” When the ALJ “make[s] a factual
determination that a [c]laimant’s subjective pain complaints are not credible in light
of medical evidence to the contrary,” “we normally defer to . . . [that] determination.”
Grindley v. Kijakazi, 9 F.4th 622, 630 (8th Cir. 2021) (quotation omitted).
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Under the revised regulations, an ALJ “will not defer or give any specific
evidentiary weight, including controlling weight, to any medical opinion(s) or prior
administrative finding(s), including those from your medical sources.” 20 C.F.R.
§ 404.1520c(a). The ALJ must evaluate the medical opinion according to the factors
listed in § 404.1520c(c). When the claimant on appeal argues the ALJ’s findings are
unpersuasive, our review under the substantial evidence standard is limited “to
whether the ALJ adequately analyzed persuasiveness . . . not whether we agree with
the ALJ’s evaluation of the record evidence on these issues.” Cropper, 136 F.4th at
814 (citation omitted). Accordingly, we uphold ALJ decisions that weigh conflicting
medical evidence and reach a conclusion that does not comport with all the medical
evidence. See, e.g., Schmitt, 27 F.4th at 1361 (“[T]he ALJ provided legitimate
reasons for discounting those opinions . . . .”).
The ALJ thoroughly evaluated PA Keller’s examination. The ALJ
acknowledged Keller’s conclusion that Bonham could not use his left arm was
“supported by the findings of muscle atrophy with 0/5 muscle strength in the left
elbow during the particular exam.” However, the ALJ concluded, it was “not
consistent with other exams during the relevant period, which showed between 3 and
5/5 muscle strength in the left upper extremity.”6 This analysis complied with
§ 404.1520c and our standard for reviewing ALJ decisions that disregard or give little
weight to disputed medical opinions. “We will not disturb an ALJ’s decision merely
because there is evidence supporting two inconsistent conclusions.” Cropper,
136 F.4th at 815 (quotation omitted). The weighing of evidence “is ultimately . . .
reserved to the [ALJ].” Cox, 495 F.3d at 619.
6Notably, even Bonham’s statements to PA Keller conflicted with his testimony
before the ALJ. During Keller’s examination, Bonham claimed that his left arm was
“useless,” but at the hearing, Bonham testified that he could still lift a two-liter bottle
of soda in his left arm during the relevant period.
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The objective medical evidence on which the ALJ relied supported the
modified light work RFC the ALJ adopted. After rejecting PA Keller’s opinion
evidence, the exams, tests, and medical source statements in the record were
sufficient to meet the substantial evidence standard and no “crucial issue” remained
undeveloped. The medical records are nearly 2,000 pages long, replete with
Bonham’s doctor and hospital visits and over a dozen physical exams that tested his
left arm. These records are sufficient to find that Bonham had strength and mobility
in his left arm and therefore could perform the functions required of a number of jobs
available in the national economy, and very likely his past relevant work as well. The
ALJ did not simply rely on her own inferences. Cf. Combs v. Berryhill, 878 F.3d
642, 646-47 (8th Cir. 2017). The physical exams and tests showed Bonham could use
his left arm, and the ALJ’s RFC reflected that. That this objective medical evidence
did not directly address some of the things Bonham may do in performing his past
relevant or other work in a workplace does not require a remand. An ALJ need not
“obtain from medical professionals a functional description that wholly connects the
dots.” Noerper, 964 F.3d at 746. “[W]e limit our review under the revised
regulations to whether the ALJ adequately analyzed persuasiveness . . . .” Cropper,
136 F.4th at 814. The ALJ’s decision to give more weight to relevant objective
evidence in the claimant’s medical records than to a one-time exam by a PA does not
create an unresolved issue that requires remanding for the development of additional
evidence to resolve the inconsistency -- even when the claimant’s attorney invites the
ALJ to do so.
Moreover, in this case, as the district court recognized, there is strong reason
to doubt that an additional expert on remand could render a reliable opinion regarding
Bonham’s ability to function in a workplace during a benefits eligibility period that
ended almost ten years ago. Due to Bonham’s five-year delay in applying for SSA
disability benefits, and his failure to present medical opinion evidence at the
administrative hearing, he failed to satisfy his burden to prove his RFC and therefore
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the ALJ’s finding that he was not disabled at steps four and five was in the acceptable
“zone of choice” and must be upheld.
For the foregoing reasons, the judgment of the district court affirming the
Commissioner’s decision is affirmed.
KELLY, Circuit Judge, dissenting.
In determining Bonham’s Residual Functioning Capacity, or RFC, the ALJ
found that Bonham “was capable of . . . lifting, carrying, pushing, or pulling 20
pounds occasionally and 10 pounds frequently; standing and walking up to 6 hours
in an eight-hour day and sitting up to 6 hours in an eight-hour workday[.]” Because
there is not sufficient evidence in the record to support these findings—and thus
insufficient evidence to support the RFC—I respectfully dissent.
In 2012, Bonham had surgery on his spine following a large disc herniation that
his doctor noted “correlated to rather profound triceps weakness and hand intrinsic
weakness.” Doctors told Bonham that his spine condition had “killed 50 percent of
the muscle in [his] arm” before surgery and, even with surgery, Bonham’s symptoms
returned in full force after about six months. From 2012 to 2016, Bonham continued
to receive medical care from treating clinicians who documented Bonham’s evolving
symptoms. As the ALJ noted, Bonham’s medical records show his left-side strength
ranged from 0/5 to 5/5 during that time. But importantly, those strength
measurements referred to different parts of his anatomy. Sometimes they referred to
his left side as a whole. Other times, they referred to specific muscles, muscle groups,
or movements, such as the left triceps, left shoulder abduction, elbow flexion, grip
strength, deep tendon reflexes, or left hand. The medical evidence also documented
problems with Bonham’s hip, knee, and ankle flexion and sensation in his left leg,
among other things.
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The ALJ relied on the numerical assessments of Bonham’s strength in
determining his lifting limitation, but no evidence in the record translates the medical
records’ strength and reflex ratings to pounds that Bonham could lift, carry, push, or
pull.7 Combs v. Berryhill, 878 F.3d 642, 646 (8th Cir. 2017) (“The ALJ ‘may not
simply draw [their] own inferences about plaintiff’s functional ability from medical
reports.’”) (quoting Strongson v. Barnhart, 361 F.3d 1066, 1070 (8th Cir. 2004)). Nor
does evidence in the record correlate, for example, elbow flexion or grip strength to
the particular movements involved in lifting, carrying, pushing, or pulling. And the
ALJ found that Bonham could sit for up to six hours and stand for up to six hours
because he had a normal gait—evidence only that he could walk normally, not sit or
stand. See Noerper v. Saul, 964 F.3d 738, 746–47 (8th Cir. 2020) (reversing and
remanding where there was “no reliable evidence providing a basis for the specific
conclusion that [claimant] can stand or walk for 6 hours in an 8-hour workday”).
As to his ability to lift, carry, push, or pull, Bonham testified that his dexterity
was so limited on his left side that he could not hold a phone or soda can, could not
tie his own shoes or buckle his belt, and could not wear clothing that had buttons.
The most he could lift with his left arm was a two-liter bottle of soda and, even then,
he could not do so with his hand alone—he had to use his whole arm, as if he were
doing a bicep curl. As to his ability to stand, walk, and sit, Bonham testified that
even just bending triggered his nerve problems, causing lower back pain, preventing
him from bending again, and making him “pretty much bedridden.” The longest he
7On appeal, Bonham cites a recent publication from the National Library of
Medicine discussing the Medical Research Council Scale for Muscle Strength, which
suggests a rating even as high as 3/5 represents only “[m]uscle activation against
gravity,” with no resistance—in other words, inability to lift any amount of weight.
Usker Naqvi, Konstantinos Margetis, & Andrew L. Sherman, Muscle Strength
Grading, Nat’l Libr. of Med. (Apr. 27, 2025), https://www.ncbi.nlm.nih.gov/books/
NBK436008/. The record here is insufficiently developed to understand whether the
clinicians who treated Bonham used this scale or a different one.
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could stand without a break was 10 minutes, and he could not sit for more than 30
minutes at a time. While the ALJ retains discretion to assess whether Bonham’s
testimony was consistent with the medical evidence and evaluate its persuasiveness
accordingly, see Ross v. O’Malley, 92 F.4th 775, 779 (8th Cir. 2024), the record here
does not allow the ALJ to determine what the medical evidence actually says about
Bonham’s limitations. As a result, the ALJ lacked the ability to properly assess
whether Bonham’s testimony was consistent—or inconsistent—with the medical
evidence.
In 2014, the VA determined Bonham was “permanently disabled” due to his
combined health conditions, including ongoing problems resulting from injuries he
sustained during his military service. Although the ALJ was not bound by that
conclusion, see Noerper, 964 F.3d at 744 (medical opinions that an applicant is
disabled or unable to work are not given controlling weight), the VA’s decision was
presumably supported by some medical evidence. Just two years later, as part of
Bonham’s compensation and pension evaluation, a clinician determined Bonham was
“unable to use his left upper extremity.” And, as the ALJ noted, “the State agency
medical and psychological consultants did not render any opinions[.]” Both
consultants wrote that “additional functional information is required to further
evaluate the claim” and identified an “absence of functional data.”
Recognizing this same deficit, Bonham twice asked the ALJ to send his file to
a medical expert (ME) to review the evidence. Bonham’s attorney explained that
“there’s no opinion evidence in this file” and “me not being an orthopedist, I
can’t—I’m just kind of reading what they’re telling us.” The ALJ stated they would
take the ME request under advisement, but never addressed the request or explained
why an ME would not be appropriate, beyond stating in the adverse determination
that an “ALJ is not required to” request one. True, but the ALJ does have “a duty to
develop the record.” Noerper, 964 F.3d at 747 (noting that because “the disability
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determination is not an adversarial process,” “[w]e have repeatedly recognized” that
the Commissioner shares a duty, alongside the claimant, to prove the claimant’s case).
I would reverse and remand this case to the ALJ for further inquiry as to the relevance
of the findings in the medical records to Bonham’s “ability to function in the
workplace.”8 Combs, 878 F.3d at 647.
______________________________
8Because I would remand to the ALJ for further proceedings, I would not reach
the issue raised in Part III.A. of the Court’s opinion.
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