Webster v. Kijakazi, 19 F.4th 715

Arthur Webster, a former truck driver and Army combat rifle crew member, alleges disability beginning March 2016 from PTSD (service‑related), and knee, foot, and back pain.
He applied for Title II disability insurance benefits; claims denied initially and on reconsideration; requested an ALJ hearing.
ALJ found medically determinable impairments but assessed an RFC for light work with occasional climbing/balancing and limitations to routine, repetitive tasks with occasional public contact; concluded Webster could perform past assembly work or other light unskilled jobs identified by a vocational expert.
Webster sought reversal; the district court (by magistrate) affirmed the ALJ, and Webster appealed to the Fifth Circuit.
On appeal Webster challenged the RFC, argued the ALJ should have ordered a consultative exam (CE), and raised listing/ability‑to‑maintain‑work claims that were not presented below.

Issue	Plaintiff's Argument	Defendant's Argument	Held
RFC unsupported by substantial evidence	ALJ failed to incorporate more restrictive state‑exam findings and improperly discounted Dr. Small’s opinion, corrupting the VE hypothetical	ALJ reasonably found state agency opinion persuasive, incorporated its limits into RFC, and permissibly discounted Dr. Small under §404.1520c standards	RFC supported by substantial evidence; ALJ properly evaluated medical opinions and used them in VE questioning
ALJ failed to order a consultative examination	Conflicting evidence (Dr. Small vs. other records) made a CE necessary to develop a full and fair record	Record contained extensive VA, hospital, state‑agency, and examiner records; no gap requiring a CE	No error: CE not required because record was sufficiently developed and ALJ had substantial evidence
Failure to analyze Listing 12.15 and ability to sustain work	ALJ did not analyze PTSD under Listing 12.15 and did not determine whether claimant could maintain employment over time	These arguments were not raised below and therefore waived on appeal	Waived: claims were not presented to the district court and are forfeited on appeal

Keel v. Saul, 986 F.3d 551 (5th Cir. 2021) (standard of review for Social Security denials)
Taylor v. Astrue, 706 F.3d 600 (5th Cir. 2012) (definition of substantial evidence)
Ripley v. Chater, 67 F.3d 552 (5th Cir. 1995) (ALJ responsible for determining RFC)
Kneeland v. Berryhill, 850 F.3d 749 (5th Cir. 2017) (requirements for rejecting medical opinions)
Bowling v. Shalala, 36 F.3d 431 (5th Cir. 1994) (vocational expert hypotheticals and counsel opportunity to correct)
Hardman v. Colvin, 820 F.3d 142 (5th Cir. 2016) (CE required only if necessary to develop a full record)
Jones v. Bowen, 829 F.2d 524 (5th Cir. 1987) (CE necessity standard)
LeMaire v. Louisiana Dep’t of Transp. & Dev., 480 F.3d 383 (5th Cir. 2007) (issues not raised below are waived)
Horton v. Bank One, N.A., 387 F.3d 426 (5th Cir. 2004) (exceptions to waiver when district court could rule on issue)