And a physical limitation that is unsupported by the record is not uncontroverted evidence, so the ALJ was not required to explicitly address it. See Wall v. Astrue, 561 F.3d 1048 (10th Cir. 2009) (noting an ALJ is only obligated to discuss “uncontroverted evidence”); Smith v. Colvin, 625 Fed.Appx. 896, 899 (10th Cir. 2015) (holding that an ALJ was not required to discuss the limiting effect of a severe impairment on each physical RFC determination); Natalie L. v. Kijakazi, 631 F.Supp.3d 1114 (D. Utah 2022), aff'd sub nom. Lager v. Comm'r, SSA, No. 22-4116, 2023 WL 6307490 (10th Cir. Sept. 28, 2023) (holding that an ALJ was not required to consider absenteeism as a result of migraines when there was no evidence in the record to support the plaintiff's assertion of the degree of absenteeism).
Judges in this court have reached the same conclusion. See, e.g., Natalie L. v. Kijakazi, 631 F.Supp.3d 1114, 1121 (D. Utah 2022), aff'd sub nom. Lager v. Comm'r, SSA, No. 22-4116, 2023 WL 6307490, at *1 (10th Cir. Sept. 28, 2023); Barbara B. v. Kijakazi, No. 1:21-CV-00094, 2022 WL 4243805, at *8 (D. Utah July 29, 2022), report and recommendation adopted, 2022 WL 3644247 (D. Utah Aug. 24, 2022), appeal dismissed sub nom.