Case Law Update: Ward-Plaster v. Commissioner — Court Remands Because ALJ Never Explained Missing Headache Limits

What happened

On October 13, 2026, a United States magistrate judge in the Middle District of Florida remanded a supplemental security income (SSI) denial to the Social Security Administration in Cheryl Ward-Plaster v. Commissioner of Social Security, No. 8:25-cv-02793-NHA (Tampa Division). The court held that the administrative law judge (ALJ) found the claimant’s headaches to be a “severe” impairment but never explained why the residual functional capacity (RFC) contained no limitations for the light sensitivity, sound sensitivity, and hearing loss she reported. The Order, signed by Magistrate Judge Natalie Hirt Adams, directs the Clerk to enter judgment in the claimant’s favor and sends the case back to the agency for further proceedings. It is not an award of benefits.

The record: daily headaches after a car accident

According to the Order, the claimant regularly complained of headaches after a January 2021 car accident, at times reporting them nearly every day. Her providers prescribed Topiramate and Ketorolac injections in late 2022, and the record showed the headaches came less often in 2023 and 2024, though she still reported frequent headaches in August 2024. She testified that some headaches faded after morning coffee while others required a trip to the doctor for a shot, and she told providers the headaches caused photophobia (light sensitivity) and interfered with her hearing.

She applied for SSI on March 8, 2022, alleging disability beginning November 2, 2021. After two hearings, the ALJ found her headaches to be a severe impairment, later citing Social Security Ruling (SSR) 19-4p, the agency’s guidance on evaluating primary headache disorders, in recognizing them. The ALJ then assigned a reduced range of light work, with no limits on light, noise, or hearing, and found she could work as a ticket seller or ticket taker. The Appeals Council denied review.

Why the court sent it back

The court did not adopt the claimant’s broadest argument. It rejected the assertion that an ALJ must add a specific RFC limitation for every severe impairment, citing the Eleventh Circuit’s unpublished decision in Castel v. Commissioner of Social Security, 355 F. App’x 260 (11th Cir. 2009). Omitting headache limitations was therefore not automatically an error.

The problem was the missing explanation. The ALJ said he had “considered all symptoms” and made a general finding that the claimant’s statements were “not entirely consistent” with the record, but, as the court put it, the decision made “no mention of whether or how he considered the related reports that they caused sensitivity to light and sound and hearing loss.” Under Wilson v. Barnhart, 284 F.3d 1219, 1225 (11th Cir. 2002), an ALJ who discounts a claimant’s subjective complaints must give “explicit and adequate reasons for doing so.”

The court noted two possibilities: the ALJ may have concluded the headaches were adequately controlled by medication, or he may have failed to consider the symptoms at all. “Without the ALJ’s providing ‘explicit and adequate reasons’ for the absence of corresponding limitations in the RFC,” the Order states, “the Court cannot meaningfully review his evaluation of them.”

On remand, the ALJ must identify on what bases he selected and excluded headache-related limitations. If he finds no light, sound, or hearing limitations, he must state why; if he finds they are needed during the workday, he must “refashion” the RFC to account for them.

The arguments the claimant lost

The Order rejected the claimant’s other two arguments. The court held that the ALJ adequately considered the combined effect of her physical and mental impairments, relying on Eleventh Circuit authority that an ALJ’s step-three finding as to an “impairment or combination of impairments” can show combined consideration. It also held that an ALJ who finds only “mild” limitation in interacting with others is not required to include a social-interaction limit in the RFC, and it rejected her argument that the ticket-seller job, which she said requires sustained public interaction, conflicted with the “mild” finding. The court found substantial evidence supported that finding, including “scant references to social deficits” on mental status examinations and her “cooperative and pleasant” demeanor on a call with the agency.

What this means if you have a headache or migraine disability claim

Every claim turns on its own record, and this Order does not predict how any other case will come out. But it highlights several practical points for claimants with chronic headaches or migraines:

• A “severe” finding is not the finish line. An ALJ can call headaches severe and still find no work-related limits. The question is whether the decision explains why.
• Name the specific symptoms. The claimant here had documented light sensitivity, sound sensitivity, and hearing complaints in both her testimony and her medical records. Specific, recurring symptoms in treatment notes give a reviewing court something concrete to measure the ALJ’s explanation against.
• Track frequency and treatment. How often headaches occur, how long they last, and what treatment they require (such as injections from a doctor) are the kinds of facts SSR 19-4p tells adjudicators to weigh.
• “Mild” mental findings are hard to challenge. The Order cites a line of Eleventh Circuit and Florida federal decisions holding that mild limitations in the four mental functional areas do not require an RFC limitation.
• A remand is a new decision, not a win. The agency will reconsider the claim; benefits are not guaranteed.

Federal court review of a Social Security denial has strict deadlines, generally 60 days from receipt of the Appeals Council’s notice under 42 U.S.C. § 405(g). For an overview of the appeals process, see our Social Security disability guide. More rulings are collected on our Case Law & Industry Insights page.

If your disability claim was denied, Louis Law Group offers a free case evaluation.

Source: Order, Doc. 25, Ward-Plaster v. Commissioner of Social Security, No. 8:25-cv-02793-NHA (M.D. Fla. Oct. 13, 2026). This article summarizes a court ruling for general information and is not legal advice. Last updated October 17, 2026.