Tammy Hesseltine v. Carolyn Colvin, 800 F.3d 461

Tammy Hesseltine applied for Title II disability benefits; ALJ denied, Appeals Council and district court affirmed; Eighth Circuit reverses and remands for further proceedings.
IQ testing: childhood score 70 (1993) but considered outdated; adult scores 71 (2005) and 72 (2012), with processing/verbal scores in the low 70s; consultative examiner found borderline intellectual functioning and very low adaptive behavior scores on some measures.
Physical impairments include Perthes disease of the left hip (leg length discrepancy, limited mobility, pain with prolonged standing), obesity, and resolved/managed polycystic ovarian syndrome; ALJ found these severe impairments.
ALJ found claimant could perform light work with limits (stand/walk 2 hours/8, sit 6 hours/8, no ladders/kneeling/crawling, simple routine tasks) and relied on vocational expert to find jobs available.
At step three the ALJ concluded Hesseltine did not meet or medically equal Listing 12.05C (intellectual disability with additional impairment) but gave only a summary conclusion and did not analyze the POMS medical-equivalence guidance.
Eighth Circuit majority held the ALJ failed to explain whether the combination of slightly-elevated IQ scores (70–75 range) plus other impairments and adaptive deficits medically equaled Listing 12.05C and remanded for further consideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether claimant's impairments medically equal Listing 12.05C	Hesseltine: IQs in 70–75 range plus adaptive deficits and physical impairments warrant medical-equivalence under POMS for 12.05C	Commissioner/ALJ: claimant's adult IQs (71,72) exceed 60–70; record supports ALJ conclusion that combination does not equal the listing	Remanded — ALJ did not explain consideration of POMS or medical-equivalence; record insufficiently explained to permit review

Phillips v. Colvin, 721 F.3d 623 (8th Cir. 2013) (elements of Listing 12.05C)
McNamara v. Astrue, 590 F.3d 607 (8th Cir. 2010) (discussing Listing 12.05C requirements)
Shontos v. Barnhart, 328 F.3d 418 (8th Cir. 2003) (ALJ must consider POMS and medical-equivalence when record suggests equivalence)
Scott ex rel. Scott v. Astrue, 529 F.3d 818 (8th Cir. 2008) (remand when ALJ findings insufficient to permit court to determine support in record)
Chunn v. Barnhart, 397 F.3d 667 (8th Cir. 2005) (remand where ALJ did not consider Listing 12.05C)
Sullivan v. Zebley, 493 U.S. 521 (1990) (standards for medical equivalence to listings)