No.
SSA regulations explain that "[t]o ambulate effectively, individuals must be capable of sustaining a reasonable walking pace over a sufficient distance to be able to carry out activities of daily living." 20 C.F.R. Part 404, Subpt. P, App. 1 ยง 1.00(2)(b)(2) (italics omitted). The regulations further provide that "examples of ineffective ambulation include . . . the inability to walk without the use of a walker, two crutches or two canes, [and] the inability to walk a block at a reasonable pace on rough or uneven surfaces." Id. Finally, the regulations note that "[t]he ability to walk independently about one's home without the use of assistive devices does not, in and of itself, constitute effective ambulation." Id.
In the case of Murdock v. Astrue (10th Cir. 2012), the ALJ concluded that Ms. Murdock had an RFC for sedentary work, but qualified the RFC by finding that "[c]laimant may also require a walker to ambulate long distances but not to stand or ambulate for short distances (less than 100 feet)."
Ms. Murdock argued, "the fact that [she] can ambulate short distances without an assistive device does not constitute effective ambulation" and the ALJ "found that [she] needed a walker if she walked more than 100 feet." As such, the ALJ's finding, by itself, is evidence of an inability to ambulate effectively." Ms. Murdock argued that, "a reasonable administrative factfinder, following the correct analysis, could have found that Murdock could not ambulate effectively."
The Court agreed with Ms. Murdock. The Court found that common sense should apply. The Court reasoned that a distance of 100 feet is not very far. To give perspective to this discussion, the distance between each base on a baseball field is 90 feet. That means that Ms. Murdock would need a walker to walk further than the distance between first base to second base, a distance that in general is much shorter than a city block. If Ms. Murdock is unable to walk a block without a walker, then she has demonstrated the inability to effectively ambulate. The Court held that ALJ's finding that Ms. Murdock may require a walker to ambulate for distances greater than 100 feet does not "conclusively negate the possibility" that she was not disabled.