Cichocki v. Astrue, 729 F.3d 172

Cichocki sought disability benefits under 42 U.S.C. § 401 et seq. after her 2009 claim was denied.
The district court granted judgment on the pleadings, finding substantial evidence supported denial.
The ALJ applied the five-step framework but did not perform a function-by-function RFC analysis at Step Four.
The ALJ found Cichocki could perform light work with specific restrictions and could perform two past jobs.
The appeals court affirmed, holding lack of explicit function-by-function analysis is not per se remand-worthy where the record supports RFC and proper standards.
The decision reviewed focuses on whether the ALJ’s Step Four RFC supports meaningful judicial review and is supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether omission of a function-by-function RFC analysis at Step Four is reversible error	Cichocki argues per se remand is required	Commissioner contends explicit analysis is not always necessary	Not per se error; remand not required when evidence supports RFC and proper standards applied

Shaw v. Chater, 221 F.3d 126 (2d Cir. 2000) (constitutional standard for evaluating RFC and steps)
Perez v. Chater, 77 F.3d 41 (2d Cir. 1996) (RFC assessment and Step Four framework guidance)
Berry v. Schweiker, 675 F.2d 464 (2d Cir. 1982) (remand permissibility based on need for clarity in ALJ reasoning)
Zatz v. Astrue, 346 F. App’x 107 (7th Cir. 2009) (approval of non-explicit function-by-function analysis when adequate)
Bayliss v. Barnhart, 427 F.3d 1211 (9th Cir. 2005) (function-by-function analysis not always required)
Delgado v. Comm’r of Soc. Sec., 30 F. App’x 542 (6th Cir. 2002) (absence of discussion of unlimiting capacities if no limitation alleged)
Depover v. Barnhart, 349 F.3d 563 (8th Cir. 2003) (function-by-function analysis not always necessary)
Shaw v. Carter, 221 F.3d 126 (2d Cir. 2000) (reaffirmation of proper five-step review)