End-Organ Effects or Explanation Required: Third Circuit Upholds ALJ’s Step‑3 Use of Record Silence and “Simple Tasks” RFC After Moderate Mental Limitations

End-Organ Effects or Explanation Required: Third Circuit Upholds ALJ’s Step‑3 Use of Record Silence and “Simple Tasks” RFC After Moderate Mental Limitations

Case: Ramon Placencia v. Commissioner of Social Security (3d Cir. No. 24-1887)

Court: United States Court of Appeals for the Third Circuit

Panel: Judges Bibas, Phipps, and Ambro (opinion by Judge Ambro)

Date: March 31, 2025

Disposition: Affirmed (Non-precedential; not binding under I.O.P. 5.7)

Introduction

This Social Security appeal concerns the Administrative Law Judge’s (ALJ) determination that claimant Ramon Placencia was not disabled between February 15, 2009 and December 4, 2012. Placencia alleged a mix of physical impairments (diabetes, hypertension, and a 2010 ministroke) and mental impairments (depression and anxiety). He challenged the ALJ’s decision on two fronts:

  • Step 3 (Listings): The ALJ purportedly failed to adequately explain why no impairment (alone or in combination) met or equaled a listed impairment.
  • Step 4 (Residual Functional Capacity): The ALJ’s finding that Placencia could perform “light” and “simple” work allegedly lacked substantial evidence.

The Third Circuit rejected both arguments. Applying the deferential substantial-evidence standard, the Court held that the ALJ reasonably concluded (1) the record lacked listing-level severity, especially given the absence of end-organ effects for diabetes and hypertension and the rapid resolution of ministroke symptoms; and (2) the record supported an RFC for light work with simple tasks in light of multiple consistent medical assessments. The Court also reaffirmed that an ALJ may:

  • Rely not only on what the record says, but also on what it does not say, when assessing listing-level severity.
  • Adopt a “simple tasks” RFC even after finding “moderate” mental limitations—so long as the ALJ explains why (per Hess v. Commissioner).

Summary of the Opinion

  • Jurisdiction and Standard: The District Court properly reviewed under 42 U.S.C. § 405(g); the Third Circuit reviewed under 28 U.S.C. § 1291 and applied substantial-evidence review: “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”
  • Step 3 (Listings): Diabetes and hypertension are not presumptively disabling absent detrimental effects on other body systems. The ALJ reasonably relied on largely unremarkable physical exams, lack of significant symptoms, and the absence of end-organ damage. The ALJ also adequately addressed the ministroke: symptoms resolved within hours, then improved and became asymptomatic, defeating listing-level severity. On mental impairments, the ALJ permissibly gave greater weight to longitudinal treatment records and state-agency reviewer Dr. Shapiro over a one-time consultative exam (Dr. Brown) with outlier findings.
  • Step 4 (RFC): Substantial evidence supported an RFC for light work and simple tasks. Multiple physicians (including post-stroke reviewers Walsh and Paolino) supported light exertion; multiple psychologists supported simple work. Distinguishing limits in pushing/pulling from those in lifting/carrying was reasonable and consistent with medical opinions. The “simple tasks” limitation coexisted permissibly with “moderate” limitations in broad areas of mental functioning because the ALJ offered a valid explanation, aligning with Hess.
  • Result: The ALJ’s findings cleared the substantial-evidence bar; the judgment affirming the Commissioner was affirmed.

Analysis

Key Precedents and Authorities Cited

  • Substantial Evidence and Appellate Deference
    • Reefer v. Barnhart, 326 F.3d 376, 379 (3d Cir. 2003) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)): defines substantial evidence as “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”
    • Williams v. Sullivan, 970 F.2d 1178, 1182 (3d Cir. 1992): appellate courts do not reweigh evidence or substitute their judgment for that of the factfinder.
    • Hartranft v. Apfel, 181 F.3d 358, 360 (3d Cir. 1999): reinforces the substantial-evidence framework and the “reasonable mind” lens.
  • Listings and Medical Equivalence
    • Sullivan v. Zebley, 493 U.S. 521, 532 (1990): listings set a higher severity threshold than the statutory definition of disability.
    • Regulations: 20 C.F.R. § 404.1525(a), (c)(3)-(4) (listings are presumptively disabling, require satisfaction of all criteria, and are often permanent or expected to be fatal); § 404.1526(a) (medical equivalence requires equal severity and duration to a listing); § 404.1529(d)(3) (symptoms cannot substitute for missing signs or laboratory findings).
    • Listing guidance for diabetes and hypertension: 20 C.F.R. pt. 404, subpt. P, app. 1 §§ 9.00B (endocrine disorders; diabetes evaluated by effects on other systems) and 4.00H.1 (hypertension evaluated by effects on other bodily systems).
  • How ALJs May Read and Explain the Record
    • Lane v. Commissioner of Social Security, 100 F. App’x 90, 95 (3d Cir. 2004) (citing Dumas v. Schweiker, 712 F.2d 1545, 1553 (2d Cir. 1983)): an ALJ may rely not only on what the record says, but also on what it does not say.
    • Cosme v. Commissioner of Social Security, 845 F. App’x 128, 132 (3d Cir. 2021): Step‑3 articulation can be read in the context of the decision as a whole; later discussion may suffice.
    • Zirnsak v. Colvin, 777 F.3d 607, 614 (3d Cir. 2014): ALJs may accept some medical evidence and reject other evidence if they provide explanations.
    • Hess v. Commissioner of Social Security, 931 F.3d 198, 212 (3d Cir. 2019): no categorical bar to using a “simple tasks” RFC after finding moderate difficulties in concentration, persistence, or pace, provided the ALJ offers a valid explanation.

Legal Reasoning

1) Step 3 – Why the Impairments Did Not Meet or Equal a Listing

The Court agreed that neither diabetes nor hypertension met or equaled a listing because the listings require measurable, detrimental effects on other organs or body systems. The ALJ cited:

  • Generally unremarkable exams aside from elevated readings.
  • No significant reported symptoms associated with diabetes or hypertension.
  • No evidence of end-organ damage, as an early reviewer expressly noted.

Against that backdrop, the ALJ could reasonably infer from the absence of end-organ findings that listing-level severity was not present. The Third Circuit expressly embraced that inferential method, citing Lane/Dumas: an ALJ may rely on what the record does not say when the listings require objective manifestations that are missing.

The ministroke reinforced the point. Though Placencia presented with slurred speech and left-sided weakness, those symptoms resolved within hours; his weakness improved within weeks; and he became asymptomatic within months. That clinical trajectory—acute onset with rapid resolution and no lasting deficits—undercut any claim of listing-level neurological impairment or medical equivalence. The ALJ articulated the listings criteria and then, as Cosme permits, explained elsewhere in the decision why the residuals did not reach listing severity.

On mental impairments, the ALJ weighed a one-time consultative exam (Dr. Brown) showing more severe findings against the broader longitudinal record and state-agency reviewers (notably Dr. Shapiro), which showed medication response and largely intact memory, concentration, and judgment. Citing Zirnsak, the Court held it was permissible to give less weight to an outlier, one-time exam when inconsistent with the treatment history and other opinions, provided the ALJ explains why—which he did.

2) Step 4 – Why the RFC for Light Work With Simple Tasks Was Supported

The ALJ’s RFC drew support from at least six expert assessments, including post‑stroke reviews:

  • Physicians Walsh (Sept. 2011) and Paolino (Mar. 2012) concluded light-exertion capacity persisted after the ministroke.
  • State-agency psychologists (Shapiro, Britton, D’Adamo) agreed Placencia could perform simple tasks.

The claimant’s argument that the RFC hinged exclusively on earlier opinions by Drs. Schneider and Shapiro was factually inaccurate; later opinions corroborated the same conclusions. Similarly, the claim that “lifting/carrying/standing/walking” allowances conflicted with a limit on “pushing/pulling” was rejected as a category error: these are distinct functional domains, and the ALJ reasonably adopted medical opinions distinguishing them.

Finally, the “simple tasks” limitation was challenged as inconsistent with the ALJ’s Step‑3 finding of “moderate” limitations in broad areas of mental functioning. The Court, citing Hess, declined to impose a categorical bar. So long as the ALJ explains why “moderate” limitations nonetheless permit simple tasks, the RFC stands. Here, the ALJ tied the simple-tasks allowance to the longitudinal record and Dr. Shapiro’s opinion; thus, the explanation was adequate.

Impact and Practical Significance

Although non-precedential, the decision offers concrete guidance in recurring Social Security disputes within the Third Circuit:

  • Diabetes/Hypertension Listings: Elevated readings alone are insufficient. Without end-organ involvement or comparable objective sequelae, listing-level severity is unmet. Claimants should marshal evidence of systemic impact if seeking Step‑3 relief; ALJs may rely on the absence of such findings.
  • Transient Neurological Events: A ministroke/TIA with rapid resolution and no persistent deficits typically will not satisfy listing criteria or medical equivalence. Documented longitudinal recovery can defeat Step‑3 arguments.
  • Weighing One‑Time Exams: ALJs may discount severe findings from a one-time consultative exam where inconsistent with longitudinal treatment records and multiple state-agency opinions, provided they explain the inconsistency.
  • “Simple Tasks” After Moderate Mental Limits: Hess remains the touchstone. An ALJ may include a “simple tasks” RFC limitation after finding moderate difficulties in concentration, persistence, or pace if the decision explains why simple work remains feasible.
  • Functional Specificity in RFC: Distinguishing among physical functions (e.g., pushing/pulling vs. lifting/carrying vs. standing/walking) is appropriate. Medical opinions often parse these functions differently; ALJs may reflect those nuances in tailored RFCs.
  • Record Silence as Evidence: The Court reaffirms that ALJs may draw reasonable inferences from the absence of expected findings where the regulations require objective signs or lab results.

Complex Concepts Simplified

  • Listings (Step 3): A catalog of medical conditions so severe that if a claimant’s impairment matches a listing’s criteria, disability is presumed. Every element of the listing must be satisfied. For diabetes and hypertension, the key is usually evidence of damage to other organs/systems caused by those conditions.
  • Medical Equivalence: Even if no listing is met exactly, a claimant can prevail at Step 3 if the impairment(s) are at least equal in severity and duration to a listing, typically shown by comparable objective medical findings.
  • Residual Functional Capacity (RFC): A practical assessment of the most a person can do despite impairments, based on all relevant evidence. It is function-by-function (e.g., sitting, standing, walking, lifting; concentration; social functioning).
  • Light Work and Simple Tasks: “Light work” is a level of physical activity reflecting lesser exertion than medium/heavy work. “Simple tasks” refers to cognitive demands, generally entailing work with basic instructions and routine operations. They address different domains: physical versus mental.
  • Substantial Evidence: A deferential standard of review. The question is not whether another view is possible, but whether a reasonable mind could accept the ALJ’s conclusion based on the record.
  • Moderate Limitations: Problems that are more than mild but not severe enough to preclude all function in a domain. A finding of “moderate” limits at Step 3 does not automatically dictate the RFC; the ALJ must explain how those limits translate into work-related capacity (e.g., limiting to “simple tasks”).

Conclusion

The Third Circuit’s decision in Placencia v. Commissioner underscores two recurring and practical points in Social Security adjudication. First, to satisfy Step‑3 listings for conditions like diabetes and hypertension, the record must document end-organ or systemic effects—not simply elevated readings—and the ALJ may reasonably rely on the absence of such findings. Second, an RFC limiting a claimant to “simple tasks” can be consistent with “moderate” mental limitations if the ALJ explains the nexus, as required by Hess.

More broadly, the decision reinforces the substantial-evidence framework: appellate courts do not reweigh the record but ask only whether a reasonable mind could reach the ALJ’s conclusions. On this record—featuring largely unremarkable physical exams, a transient neurological event, improvement with medication, and multiple consistent expert assessments—the ALJ’s findings were adequately explained and supported. While non-precedential, the opinion offers clear practical guidance for assembling, weighing, and challenging evidence in disability cases, particularly where alleged listing-level impairments hinge on objective end-organ involvement and where mental limitations must be translated into concrete RFC terms.

Case Details

Year: 2025
Court: Court of Appeals for the Third Circuit

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