Clarifying ALJ’s Articulation Requirements Under SSR 17-2p for Medical Equivalence Findings

Introduction

Melisha A. Salisbury v. Commissioner of Social Security, No. 24-3898 (6th Cir. Apr. 11, 2025) arises from Salisbury’s challenge to the denial of Disability Insurance Benefits (DIB). Salisbury, diagnosed with multiple sclerosis (MS) and a host of related impairments, argued that her condition “medically equals” the criteria of Listing 11.09(A) for MS—namely, disorganization of motor function in two extremities with an extreme limitation in standing, balance or use of upper extremities. The key issue on appeal was whether the Administrative Law Judge (ALJ) adequately articulated reasons for rejecting the opinion of the Social Security–hired medical expert, Dr. Geneve, who had concluded medical equivalence to Listing 11.09(A).

Summary of the Judgment

The Sixth Circuit affirmed. The ALJ had conducted a full sequential evaluation:

At Step 3, determined Salisbury did not meet or medically equal Listing 11.09(A).
Assigned “no weight” to Dr. Geneve’s interrogatory opinion—finding it unexplained and unsupported by objective exam findings.
Found, at Step 4, a residual functional capacity (RFC) for a limited range of sedentary work with a single-cane restriction.
At Step 5, concluded Salisbury could perform other work existing in significant numbers.

The district court adopted a magistrate judge’s report and recommendation, and the Sixth Circuit, reviewing de novo, held that the ALJ applied correct legal standards and that substantial evidence supported his findings.

Analysis

Precedents Cited

The court’s reasoning draws on:

20 C.F.R. § 404.1520: the five-step sequential evaluation process.
20 C.F.R. Pt. 404, Subpt. P, App. 1, § 11.09(A): Listing criteria for MS.
Social Security Ruling (SSR) 17-2p (2017): guidance on treating medical-expert interrogatories regarding medical equivalence.
Bowen v. Yuckert, 482 U.S. 137 (1987) and Foster v. Halter, 279 F.3d 348 (6th Cir. 2001): allocation of burden to establish meeting or equaling a listing.
Blakley v. Commissioner, 581 F.3d 399 (6th Cir. 2009) and Warner v. Commissioner, 375 F.3d 387 (6th Cir. 2004): standards for substantial‐evidence review.
Bledsoe v. Barnhart, 165 F. App’x 408 (6th Cir. 2006): no heightened articulation requirement where substantial evidence exists.
Garland v. Ming Dai, 593 U.S. 357 (2021): agencies need not use “magic words” or a rigid formula.

Legal Reasoning

1. Step 3 Equivalence Requirements. To equal Listing 11.09(A), claimant must show “disorganization of motor function” in two extremities—i.e., interference with movement caused by a neurological disorder—and an “extreme limitation” in standing up, balance, walking or use of upper extremities, without two-point assistive devices.

2. ALJ’s Consideration of Dr. Geneve. Under SSR 17-2p, if an ALJ disagrees with a medical expert’s conclusion on equivalence, the ALJ need only make a general statement that the claim does not equal a listing; extensive point‐by‐point rebuttal is not required so long as the record discussion enables meaningful review.

3. Substantial Evidence. The ALJ catalogued dozens of examination findings—motor strength, gait, station, proprioception—spanning 2015–2021. Most records showed normal or near-normal results, with Salisbury unassisted or using only a single cane. These objective data constituted substantial evidence to reject an “extreme limitation” finding.

4. Standard of Review. The Sixth Circuit reviewed de novo whether correct legal standards were applied and whether substantial evidence supports the ALJ’s decision. Finding no error, the court affirmed.

Impact

This decision reinforces that:

ALJs have wide latitude to articulate equivalence findings succinctly under SSR 17-2p.
No heightened “magic words” are needed—so long as the written decision shows the record was considered in full.
Objective medical evidence remains the gold standard for denying equivalence to a listing.

Future claimants and practitioners should ensure that ALJ decisions reflect a clear survey of the record, but need not expect line-by-line refutation of every medical-expert interrogatory.

Complex Concepts Simplified

Medical Equivalence: Claimant’s impairments need not precisely match a listing’s criteria, but their overall severity and functional limitations must equal the listing’s requirements.
Disorganization of Motor Function: Neurological interference with movement in two extremities—manifested by weakness, imbalance or coordination issues.
Extreme Limitation: Inability to stand, balance or use arms without help from another person or two-point assistive devices (walker, two canes, etc.).
Residual Functional Capacity (RFC): The most a claimant can still do despite her impairments, assessed in terms of exertional and non-exertional work activities.
Substantial Evidence: “Such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”

Conclusion

Salisbury v. Commissioner clarifies the ALJ’s articulation obligations when a medical expert opines that a claimant’s impairments medically equal a listing. The Sixth Circuit affirms that a concise statement—supported by a thorough review of exam records—satisfies SSR 17-2p and the substantial-evidence standard. By underscoring this principle, the decision promotes efficiency in administrative proceedings while safeguarding claimants’ rights to reasoned decisions that enable meaningful judicial review.