4. Governing Framework and Legal Reasoning
A. The Five-Step Process and the Limited Scope of the Appeal
The Social Security disability evaluation proceeds through five steps under 20 C.F.R. § 404.1520:
- Whether the claimant is engaged in substantial gainful activity.
- Whether the claimant has a severe impairment.
- Whether the impairment meets or medically equals a listed impairment.
- Whether the claimant can perform past relevant work, considering residual functional capacity.
- Whether the claimant can adjust to other work.
Noe satisfied the first two steps. The ALJ found no substantial gainful activity after the alleged onset date and identified severe impairments consisting of ADHD, borderline intellectual functioning, depression, and anxiety.
Those findings did not themselves establish disability. An impairment can be “severe” at step two without meeting the substantially more demanding requirements of a listing at step three.
The ALJ found that Noe’s impairments did not meet or equal the relevant listings and ultimately denied benefits at step five. This distinction matters: failure at step three does not automatically end a disability claim. It means that the claimant does not qualify through the listings and must proceed through the remaining steps. The appellate court’s analysis concerned only the challenged step-three findings, not an independent review of the later vocational determinations.
B. The Paragraph B Requirements
The ALJ considered Listings 12.04, covering depressive, bipolar, and related disorders; 12.06, covering anxiety and obsessive-compulsive disorders; and 12.11, covering neurodevelopmental disorders.
Listings 12.04 and 12.06 may be satisfied through paragraphs A and B or paragraphs A and C. Listing 12.11 requires paragraphs A and B. Noe’s appellate challenge concerned paragraph B, which evaluates four areas:
- Understanding, remembering, or applying information;
- Interacting with others;
- Concentrating, persisting, or maintaining pace; and
- Adapting or managing oneself.
The applicable scale runs from none to mild, moderate, marked, and extreme. Paragraph B requires an extreme limitation in one domain or marked limitations in two domains. A moderate limitation means that functioning independently, appropriately, effectively, and on a sustained basis is “fair”; a marked limitation means that such functioning is seriously limited; and an extreme limitation means inability to function in that manner.
The ALJ rated every domain as moderate. The appeal therefore turned on whether the evidence required rejection of those ratings. The court did not separately resolve a paragraph C challenge or develop an independent medical-equivalence analysis.
C. The Treating Psychiatrist’s Letter
Dr. Kelty began treating Noe in March 2021. In a September 1, 2022 letter, he described suspected diagnoses and reported that Noe had been so disorganized at her initial appointment that she could not participate meaningfully in conversation. Much of the remaining letter summarized observations from family members and acquaintances after his review of earlier psychological evaluations and school records.
He concluded that Noe could not maintain gainful and substantial employment and that this had likely been true throughout her adult life.
The court distinguished that ultimate conclusion from evidence about symptoms and functioning. Whether a claimant is disabled or unable to work is a determination reserved to the Commissioner under 20 C.F.R. § 404.1520b(c)(3)(i). Accordingly, the court held that the ultimate conclusion was not entitled to weight and did not require an explanation of its value.
The court supplied two additional reasons for rejecting Noe’s argument:
- The underlying third-party evidence summarized in the letter appeared elsewhere in the record and had been reviewed by the ALJ.
- The ALJ had actually explained that the opinion was conclusory, addressed the ultimate disability issue, and conflicted with Dr. Kelty’s clinical findings.
The holding should not be read as permitting an ALJ to disregard all clinical evidence merely because a physician also expresses an opinion on disability. Its core distinction is between evidence of functional limitations and a conclusion that the statutory disability standard has been met.
D. Application to the Four Functional Domains
Understanding, Remembering, or Applying Information
The ALJ relied on Noe’s intelligence testing, educational history, learner’s permit, clinical findings, and hearing responses. Childhood testing showed borderline-to-low-average verbal abilities and moderately low overall performance on another measure, but also memory strengths. Testing at age 23 placed her overall functioning in the low-average range and her verbal IQ in the average range.
Noe also graduated from high school in general education classes, attended some college, and eventually passed a driving-permit test. More recent clinicians described aspects of her judgment, insight, and memory as appropriate or intact. Her hearing answers, although not always clear, were responsive.
The court acknowledged qualifications to that evidence: Noe received educational accommodations and passed the permit test only on her seventh attempt. Those facts showed difficulty, but did not compel a finding more restrictive than moderate. The decision does not establish that graduation or obtaining a permit categorically excludes marked limitations.
Interacting with Others
The record contained substantial conflict. Acquaintances described longstanding difficulty with eye contact, conversation, and social engagement. Other evidence showed that Noe enjoyed familiar people, socialized with school friends, and had no identified social-competence concerns in a ninth-grade report.
The ALJ also cited her friendship with the family’s housekeeper, interactions with patients at her father’s medical office, appropriate socialization findings in 1992 testing, cooperative clinical behavior, and polite hearing responses.
The court upheld the moderate rating because those supporting observations were grounded in the record. It did not find that the adverse accounts were nonexistent or necessarily unreliable; rather, their presence did not eliminate substantial support for the ALJ’s assessment.
Concentrating, Persisting, or Maintaining Pace
The ALJ recognized Noe’s ADHD and documented problems with focus, directions, and remaining on task. Nevertheless, a November 2022 examination recorded no reported decreased concentration and described attention and perception as normal.
Noe relied on third-party accounts of distraction and school records describing slow work. The court characterized the cited third-party examples as isolated incidents and concluded that they did not compel a marked or extreme rating, particularly given the limited supporting medical evidence.
This analysis illustrates the difference between identifying symptoms and establishing their listing-level functional severity. A diagnosis and examples of difficulty were relevant, but did not automatically determine the required rating.
Adapting or Managing Oneself
Noe testified that she could attend to personal hygiene, feed pets twice daily, walk them, prepare simple meals, and visit fast-food restaurants with friends. The ALJ also considered her educational history and learner’s permit.
The Sixth Circuit found that these activities supplied substantial evidence for a moderate limitation. Their significance was specific to the challenged functional domain. The opinion did not hold that performing basic household tasks, by itself, demonstrates an ability to sustain full-time employment.
E. Conflicting Evidence and Historical Onset
The court expressly accepted that some evidence could support more severe limitations. Its task, however, was not to choose the interpretation it found most persuasive, but to determine whether the ALJ’s interpretation had substantial evidentiary support and complied with governing law.
The historical onset requirements add an important qualification. Noe needed to establish disability before the applicable 2000 or 2008 deadline, although some evidence discussed in the opinion came from 2021 and 2022. The court considered a record spanning school years, early adulthood, and recent treatment, but did not articulate a separate rule governing retrospective proof. The decision should therefore not be read as holding that later normal findings necessarily disprove earlier disability.
5. Precedents Cited and Their Influence
Moats v. Comm'r of Soc. Sec., 42 F.4th 558, 561 (6th Cir. 2022)
The court cited this decision for de novo review of the district court’s judgment in a Social Security appeal. That standard allows the appellate court to assess the district court’s legal disposition independently. It does not authorize a fresh weighing of the administrative evidence.
Napier v. Comm'r of Soc. Sec., 127 F.4th 1000, 1004 (6th Cir. 2025)
This decision supplied the controlling description of review of the ALJ’s decision: the court asks whether substantial evidence supports it and whether proper legal standards were applied. Quoting Rogers v. Comm'r of Soc. Sec., it framed both principal issues in Noe’s appeal—the evidentiary support for the functional ratings and the legality of the treatment of Dr. Kelty’s conclusion.
Rogers v. Comm'r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)
The opinion used this precedent both through the quotation in Napier v. Comm'r of Soc. Sec. and directly. Its central contribution was the principle that a reviewing court must affirm a substantially supported administrative decision even if the court might have reached a different result.
That principle explains why Noe’s contrary evidence did not itself establish reversible error. At the same time, the proper-legal-standards requirement means that evidentiary deference does not excuse application of an incorrect rule.
Ferguson v. Comm'r of Soc. Sec., 628 F.3d 269, 275 (6th Cir. 2010)
The court cited this decision for Noe’s burden to prove disability. In the step-three dispute, that burden required proof of the functional severity demanded by the listings, not merely proof of diagnoses or meaningful impairment. The court invoked that allocation of responsibility when assessing the sparse record.
Gayheart v. Comm'r of Soc. Sec., 710 F.3d 365, 374 (6th Cir. 2013)
This decision furnished the opinion’s concluding principle: an administrative decision supported by substantial evidence may be affirmed even when substantial evidence could also support the opposite result. It directly answered Noe’s contention that evidence of greater limitations required reversal.
The court relied on this case for that review principle; the opinion did not undertake a broader analysis of other doctrines that the precedent may address.