Date: Feb 11, 2026

Williams v. Bisignano: SSR 17-2p Permits a Bare Step-Three “No Medical Equivalence” Statement When Later Findings Supply the Rationale

Introduction

In Williams v. Bisignano (5th Cir. Feb. 9, 2026) (per curiam) (unpublished), Scott Williams sought Disability Insurance Benefits (Title II) and Supplemental Security Income (Title XVI), alleging disability beginning March 2020 due to anxiety. After an Administrative Law Judge (ALJ) denied benefits and the Appeals Council declined review, Williams sought judicial review in the Eastern District of Louisiana and then appealed.

The appeal focused on two stages of the Social Security Administration’s five-step framework: step three (whether impairments meet or medically equal a listed impairment) and step five (whether other work exists in significant numbers given the claimant’s residual functional capacity). Williams’s principal contentions were (1) the ALJ failed to explicitly articulate a “medical equivalence” analysis at step three, and (2) the ALJ’s vocational hypothetical did not incorporate all mental limitations reflected in a state-agency psychologist’s findings.

Summary of the Opinion

The Fifth Circuit affirmed. On step three, the court held that under SSR 17-2p, an ALJ’s statement that impairments do not medically equal a listing generally constitutes sufficient articulation, and any additional rationale may be supplied by the ALJ’s explanations at later steps. The court rejected Williams’s argument that SSR 17-2p is unlawful or inconsistent with the regulations.

On step five, the court held that the ALJ’s hypothetical properly tracked the ALJ’s reasoned residual functional capacity (RFC), which was informed by the psychologist’s narrative mental RFC (MRFC). The court also rejected Williams’s attempt to convert “moderate” checkbox limitations into a work-preclusive “off-task 15–20%” construct that did not match the agency’s definition or the psychologist’s narrative.

Analysis

Precedents Cited

Keel v. Saul, 986 F.3d 551 (5th Cir. 2021) and Whitehead v. Colvin, 820 F.3d 776 (5th Cir. 2016) (per curiam): The court relied on these cases for the governing standard of review—whether the final decision is supported by substantial evidence and whether proper legal standards were applied.
Biestek v. Berryhill, 587 U.S. 97 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197 (1938)): These authorities framed “substantial evidence” as a relatively low evidentiary threshold, reinforcing the court’s deference to administrative factfinding when the record reasonably supports the ALJ’s conclusions.
Johnson v. Bowen, 864 F.2d 340 (5th Cir. 1988) (per curiam): Cited for the proposition that reversal is appropriate only when no credible evidentiary choices or medical findings support the decision.
Garcia v. Berryhill, 880 F.3d 700 (5th Cir. 2018): Used (through Keel) to restate the five-step sequential evaluation.
Bowling v. Shalala, 36 F.3d 431 (5th Cir. 1994): Provided the key rule governing vocational expert hypotheticals: the ALJ must incorporate reasonably all disabilities recognized by the ALJ. The court used Bowling to assess whether the RFC-based hypothetical properly captured the limitations the ALJ found supported by the record.
Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024): Williams invoked Loper Bright to contest deference to agency interpretation. The Fifth Circuit found it unnecessary to decide Loper Bright’s applicability because Williams’s challenge failed even without deference—there was no demonstrated conflict between SSR 17-2p and the regulations.

Legal Reasoning

1) Step Three: Articulation of Medical Equivalence Under SSR 17-2p

The ALJ found that Williams’s mental impairments did not meet or medically equal the criteria of Listings 12.04, 12.06, and 12.11, referencing the alternative paths to satisfaction (Paragraph B and, for 12.04/12.06, Paragraph C). Williams did not dispute the ALJ’s severity findings in the abstract; instead, he argued the ALJ had to explicitly analyze medical equivalence.

The Fifth Circuit treated SSR 17-2p as controlling agency policy on articulation: an ALJ’s statement that an impairment does not medically equal a listing “constitutes sufficient articulation,” and the ALJ’s reasoning at later steps may provide enough rationale for a reviewing court to understand the step-three equivalence finding.

Williams attempted to invalidate SSR 17-2p by arguing conflict with 20 C.F.R. §§ 404.1526(b) and 416.926. The court rejected that claim on a textual basis: the cited regulations describe what the adjudicator must consider in evaluating equivalence (e.g., 20 C.F.R. § 404.1526(c)) but do not impose an articulation requirement of the kind Williams demanded. Without a regulatory articulation mandate, SSR 17-2p was not shown to be inconsistent, and the ALJ’s explanation across the decision was sufficient for review.

2) Step Five: RFC, MRFC Narratives, and “Moderate” Limitations in Vocational Hypotheticals

On step five, the ALJ relied on a vocational expert’s testimony elicited through a hypothetical that mirrored the ALJ’s RFC “word-for-word.” Williams argued that the hypothetical failed to incorporate “moderate” limitations noted by state-agency psychologist Dr. Constantin in sub-questions about concentration and persistence.

The court drew a critical distinction between (a) checkbox-style ratings used as inputs and (b) the clinician’s narrative MRFC synthesis. Dr. Constantin’s MRFC narrative concluded that, despite deficits, Williams could “understand, remember, and carry out simple tasks with routine training and supervision.” The ALJ used that narrative (along with the rest of the record) to craft the RFC; therefore, the RFC-based hypothetical incorporated the limitations the ALJ recognized as supported.

The court also rejected Williams’s reliance on the vocational expert’s cross-examination answers because Williams’s counsel had redefined “moderate impairment” to mean being “unable to do the task of duty satisfactorily” for “15 to 20 percent” of the workday. That definition did not align with the agency’s definition on the form used by Dr. Constantin, which defined “moderately limited” to mean the individual’s “capacity to perform the activity is impaired,” with the “degree and extent” to be described in narrative format. The court cited Program Operations Manual System DI 24510.063(B)(2) for that definition and narrative requirement. Because the cross-examination premise did not reflect Dr. Constantin’s usage or narrative conclusions, it did not show an omission in the ALJ’s hypothetical.

Impact

Step-three practice (articulation): The decision reinforces that, at least in the Fifth Circuit, claimants face an uphill battle challenging step-three medical equivalence findings on “insufficient articulation” grounds when the ALJ (i) states no equivalence and (ii) provides a decision that explains the functional evidence elsewhere—consistent with SSR 17-2p.
Agency policy vs. regulation challenges post–Loper Bright: The court signaled that even in a post–Loper Bright environment, a litigant must still identify an actual statutory or regulatory conflict; generalized anti-deference arguments will not carry the day where the text does not impose the requirement the litigant asserts.
Vocational testimony disputes: The opinion underscores that counsel-driven redefinitions of rating terms (like “moderate”) may be discounted when they diverge from the agency’s defined meaning and the clinician’s narrative MRFC. Challenges are more likely to succeed when they identify a concrete mismatch between the ALJ’s RFC findings and the hypothetical presented to the vocational expert.

Complex Concepts Simplified

Listings / “meet” vs. “medically equal”: The Listings are a regulatory catalog of impairments considered so severe that a claimant is presumed disabled if the criteria are satisfied. To “meet” a listing, a claimant must satisfy the listing’s stated criteria. To “medically equal” a listing, the claimant’s impairment(s), while not matching the criteria exactly, must be medically comparable in severity and duration.
Paragraph B and Paragraph C: For certain mental health listings, Paragraph B measures the degree of functional limitation across broad domains (e.g., understanding, interacting, concentrating, adapting). Paragraph C provides an alternative route for some listings, requiring proof the condition is “serious and persistent” over time.
Substantial evidence: A deferential review standard: the court asks only whether the record contains enough relevant evidence that a reasonable mind could accept to support the ALJ’s findings—not whether the court would decide the facts differently.
RFC vs. MRFC: RFC is the ALJ’s ultimate finding of what the claimant can still do in a work setting despite limitations. MRFC is a medical (often state-agency) narrative assessment synthesizing mental limitations; ALJs consider MRFC but are not required to adopt every checkbox limitation if the narrative and overall evidence supports a different functional formulation.
Vocational expert hypothetical: The ALJ poses a hypothetical person with specified limitations. If the limitations in the hypothetical match the ALJ’s supported RFC findings, vocational expert testimony can establish that jobs exist in significant numbers that the claimant can perform.

Conclusion

Williams v. Bisignano cements two practical points. First, under SSR 17-2p, an ALJ need not provide an elaborate, stand-alone step-three medical equivalence discussion so long as the decision, read as a whole, supplies a reviewable rationale for the “no equivalence” finding. Second, in step-five disputes, courts will focus on whether the ALJ’s RFC-based hypothetical reflects the limitations the ALJ actually found supported—rather than counsel’s recharacterization of “moderate” checkbox ratings into work-preclusive functional terms not used by the medical source or the agency’s own definitions.