Paul Scott v. Nancy A. Berryhill, 855 F.3d 853

Paul Scott applied for Supplemental Security Income in Jan 2013 alleging disability from a back condition, migraines, hearing loss, and a left eye injury; alleged onset Oct 15, 2012.
Education: did not finish 8th grade; history of special education; IQ testing showed full-scale IQ of 63.
Work history: performed unskilled and semi-skilled jobs (animal caretaker/farm work, construction, power plant cleaner) and stopped working in 2012 because of back pain, not mental limitations.
ALJ found two severe impairments: borderline intellectual functioning and a back disorder; did not find Listing 12.05C met (no demonstrated adaptive deficits before age 22).
ALJ assessed RFC for medium, unskilled work limited to rote tasks, minimal interpersonal contact, brief/simple supervision, and no making change; VE identified jobs (cleanup worker, poultry hanger) available in significant numbers.
Appeals Council denied review; district court affirmed; Scott appealed to the Eighth Circuit challenging the Listing 12.05C finding and the adequacy of the RFC hypothetical.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Scott meets Listing 12.05C (intellectual disability)	Scott: IQ 63 plus special-education history, school failure, inability to manage money, and limited literacy show adaptive deficits manifesting before 22	Commissioner: despite low IQ and academics, Scott’s activities, independent living, and long work history show no demonstrated adaptive deficits before 22	Court: Affirmed ALJ — substantial evidence supports finding that Scott did not demonstrate requisite adaptive deficits before age 22
Whether the RFC/hypothetical adequately captured limitations in concentration, persistence, or pace	Scott: VE hypothetical failed to capture concrete consequences of deficits in concentration, persistence, or pace	Commissioner: RFC limited task complexity, required rote performance, brief/simple supervision, and restricted math/interpersonal demands — these capture consequences	Court: Affirmed ALJ — hypothetical sufficiently captured concrete consequences and supported VE testimony

Perkins v. Astrue, 648 F.3d 892 (standard of review for ALJ factual findings)
Goff v. Barnhart, 421 F.3d 785 (substantial-evidence review and weighing contrary evidence)
Lacroix v. Barnhart, 465 F.3d 881 (vocational-expert hypothetical must capture concrete consequences)
Newton v. Chater, 92 F.3d 688 (limitation to simple work may be insufficient for pace/attendance deficits)
Lott v. Colvin, 772 F.3d 546 (evidence needed to show onset of intellectual/adaptive deficits before age 22)
Ash v. Colvin, 812 F.3d 686 (work history and daily activities can rebut adaptive-deficit showing)
Maresh v. Barnhart, 438 F.3d 897 (Listing 12.05C requires adaptive deficits manifested before age 22)
Muncy v. Apfel, 247 F.3d 728 (IQ stability presumption over time)