POSSO v. COMMISSIONER OF SOCIAL SECURITYPOSSO v. COMMISSIONER OF SOCIAL SECURITY
This matter comes before the Court pursuant to Section 205(g) of the Social Security Act, as amended,
I. PROCEDURAL HISTORY
On March 1, 2023, Plaintiff protectively filed a Title II application for a period of disability and disability insurance benefits, alleging that she had been disabled since an alleged
In a decision dated December 30, 2024, the ALJ concluded that Plaintiff was not disabled within the meaning of the Social Security Act from April 30, 2022, the alleged onset date, through the date of the decision. R. 10–18. That decision became the final decision of the Commissioner of Social Security when the Appeals Council declined review on October 2, 2025. R. 1–6. Plaintiff timely filed this appeal pursuant to
II. LEGAL STANDARD
A. Standard of Review
In reviewing applications for Social Security disability benefits, this Court has the authority to conduct a plenary review of legal issues decided by the ALJ. Knepp v. Apfel, 204 F.3d 78, 83 (3d Cir. 2000). In contrast, the Court reviews the ALJ‘s factual findings to determine if they are supported by substantial evidence. Sykes v. Apfel, 228 F.3d 259, 262 (3d Cir. 2000); see also
Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficien[t] evidence to support the agency‘s factual determinations. And whatever the meaning of substantial in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is more than a mere scintilla. It means – and means only – such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
Biestek v. Berryhill, 587 U.S. 97, 102–03 (2019) (internal citations and quotation marks omitted); see also Pierce v. Underwood, 487 U.S. 552, 565 (1988) (citation and internal quotations omitted); Bailey v. Comm‘r of Soc. Sec., 354 F. App‘x 613, 616 (3d Cir. 2009) (citations and quotations omitted); K.K. ex rel. K.S. v. Comm‘r of Soc. Sec., No. 17-2309, 2018 WL 1509091, at *4 (D.N.J. Mar. 27, 2018).
The substantial evidence standard is a deferential standard, and the ALJ‘s decision cannot be set aside merely because the Court “acting de novo might have reached a different conclusion.” Hunter Douglas, Inc. v. NLRB, 804 F.2d 808, 812 (3d Cir. 1986); see, e.g., Fargnoli v. Massanari, 247 F.3d 34, 38 (3d Cir. 2001) (“Where the ALJ‘s findings of fact are supported by substantial evidence, we are bound by those findings, even if we would have decided the factual inquiry differently.”) (citing Hartranft v. Apfel, 181 F.3d 358, 360 (3d Cir. 1999)); K.K., 2018 WL 1509091, at *4 (“‘[T]he district court ... is [not] empowered to weigh the evidence or substitute its conclusions for those of the fact-finder.’”) (quoting Williams v. Sullivan, 970 F.2d 1178, 1182 (3d Cir. 1992)).
Nevertheless, the Third Circuit cautions that this standard of review is not “a talismanic or self-executing formula for adjudication.” Kent v. Schweiker, 710 F.2d 110, 114 (3d Cir. 1983) (“The search for substantial evidence is thus a qualitative exercise without which our review of social security disability cases ceases to be merely deferential and becomes instead a sham.”);
Although the ALJ is not required “to use particular language or adhere to a particular format in conducting [the] analysis,” the decision must contain “sufficient development of the record and explanation of findings to permit meaningful review.” Jones v. Barnhart, 364 F.3d 501, 505 (3d Cir. 2004) (citing Burnett v. Comm‘r of Soc. Sec., 220 F.3d 112, 119 (3d Cir. 2000)); see K.K., 2018 WL 1509091, at *4. The Court “need[s] from the ALJ not only an expression of the evidence s/he considered which supports the result, but also some indication of the evidence which was rejected.” Cotter, 642 F.2d at 705-06; see Burnett, 220 F.3d at 121 (“Although the ALJ may weigh the credibility of the evidence, [s/]he must give some indication of the evidence which [s/]he rejects and [the] reason(s) for discounting such evidence.”) (citing Plummer v. Apfel, 186 F.3d 422, 429 (3d. Cir. 1999)). “[T]he ALJ is not required to supply a comprehensive explanation for the rejection of evidence; in most cases, a sentence or short
Unless the [ALJ] has analyzed all evidence and has sufficiently explained the weight [s/]he has given to obviously probative exhibits, to say that [the] decision is supported by substantial evidence approaches an abdication of the court‘s duty to scrutinize the record as a whole to determine whether the conclusions reached are rational.
Gober, 574 F.2d at 776; see Schonewolf, 972 F. Supp. at 284-85.
Following review of the entire record on appeal from a denial of benefits, the Court can enter “a judgment affirming, modifying, or reversing the decision of the [Commissioner], with or without remanding the cause for a rehearing.”
B. Sequential Evaluation Process
The Social Security Act establishes a five-step sequential evaluation for determining whether a plaintiff is disabled within the meaning of the statute.
At step one, the ALJ determines whether the plaintiff is currently engaged in substantial gainful activity.
At step two, the ALJ decides whether the plaintiff has a “severe impairment” or combination of impairments that “significantly limits [the plaintiff‘s] physical or mental ability to do basic work activities[.]”
At step three, the ALJ decides whether the plaintiff‘s impairment or combination of impairments “meets” or “medically equals” the severity of an impairment in the Listing of Impairments (“Listing”) found at
At step five, the ALJ must decide whether the plaintiff, considering the plaintiff‘s RFC, age, education, and work experience, can perform other jobs that exist in significant numbers in the national economy.
III. ALJ DECISION AND APPELLATE ISSUES
Plaintiff was 60 years old on the alleged disability onset date. R. 15. The ALJ found that Plaintiff met the insured status requirements of the Social Security Act through March 31, 2028. R. 12. At step one, the ALJ found that the Plaintiff had not engaged in substantial gainful activity since April 30, 2022, her alleged onset date. R. 13.3
At step two, the ALJ found that Plaintiff suffered from the following severe impairments: spine disorder; left knee internal derangement; bilateral hand osteoarthritis, with bilateral carpal tunnel syndrome; and obesity. Id. The ALJ also found that the Plaintiff had non-severe impairments, including “right medial epicondylitis. . .[and] right knee impairment,” that had not
At step three, the ALJ found that Plaintiff did not suffer an impairment or combination of impairments that met or medically equaled the severity of any Listing. R. 13–14.
At step four, the ALJ found that Plaintiff had the RFC to perform “light work,” subject to various non-exertional limitations. R. 14–18. The ALJ also found that the Plaintiff was able to perform her past relevant work as a clerk typist.4 R. 17–18. The ALJ therefore concluded that Plaintiff was not disabled within the meaning of the Social Security Act from April 30, 2022, her alleged onset date, through the date of that decision. R. 18.
Plaintiff disagrees with the ALJ‘s findings at step four and asks that the decision of the Commissioner be reversed and remanded for further proceedings. Plaintiff‘s Brief, ECF No. 9 (“Pl. Br.”); Plaintiff‘s Reply Brief, ECF No. 12 (“Pl. Reply”). Specifically, Plaintiff contends that the ALJ erred because the RFC finding fails to reasonably describe the “total limiting effects” of Plaintiff‘s hand impairments as demonstrated by the record. Pl. Br. at 8.
The Commissioner takes the position that his decision should be affirmed in its entirety because the ALJ‘s decision correctly applied the governing legal standards, reflected consideration of the entire record, and was supported by sufficient explanation and substantial evidence. Defendant‘s Brief, ECF No. 11 (“D. Br.”).
IV. SUMMARY OF ALJ FINDINGS, HEARING TESTIMONY, AND RELEVANT MEDICAL EVIDENCE
In his decision, at step three, the ALJ found that the most relevant listings implicated by Plaintiff‘s impairments were listings “1.15 (Disorders of the skeletal spine resulting in
Plaintiff does not challenge the ALJ‘s findings in this regard. Her challenge is based on the ALJ‘s RFC determination. In his decision, the ALJ noted that Plaintiff testified that she was formerly a judicial clerk, who has carpal tunnel syndrome and is no longer working. R. 15. He noted that she testified that she has “difficulty using her hands to wash dishes,” “does not use a computer at home,” and that “her arms hurt when doing laundry.” Id. He noted that she also testified that she had other symptoms related to her shoulder and knees, causing her difficulty in lifting, walking, sitting for 15 to 20 minutes until she has pain. Id. She further testified that she no longer drives; her family members help with chores; but “[o]n a typical day, she gets up with her husband and has coffee,” and “can prepare a sandwich for lunch.” Id.
Based on her medically determinable impairments, the ALJ found that the record was inconsistent with her claims about the intensity, persistence and limiting effects, noting that the limitations were reflected in his RFC finding. R. 15. The ALJ proceeded to review Plaintiff‘s history of pain in the lumbar spine, and cervical spine, as well as her right shoulder and knees, including the results of examinations and prescribed treatments. R. 15-16. He also considered the record evidence relating to Plaintiff‘s obesity and based on “the objective medical evidence of record regarding the claimant‘s impairments,” found that Plaintiff “is limited to light work, subject to the additional limitations specified in the [RFC].” R. 17.
[T]he claimant has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except: The claimant can handle and finger frequently, bilaterally. The claimant can occasionally climb ramps and stairs, never climb ladders, ropes or scaffolds, can occasionally balance as defined in the SCO, and can occasionally stoop, kneel, crouch, and crawl. The claimant can never work at unprotected heights or around hazardous moving mechanical parts and can occasionally work in extreme cold.
R. 14, 17.
When asked whether a hypothetical individual with this RFC could perform Plaintiff‘s past work, the vocational expert answered that they would “as generally performed.” R. 17, 38–39. The expert further testified that “even if the residual functional capacity were reduced to the light exertional level, that the claimant could still perform this past relevant work as generally performed.” Id. The ALJ found the expert‘s response to be “largely consistent” with the Dictionary of Occupational Titles. R. 18
V. DISCUSSION
Plaintiff challenges the ALJ‘s determination on the grounds that the ALJ fails to reasonably describe and account for the limiting effects of Plaintiff‘s hand impairments in the RFC, and failed to connect his RFC finding to the record. Pl. Br. at 8, 13; Pl. Reply at 4–5.
A claimant‘s RFC is the most that the claimant can do despite her limitations.
In addition, an ALJ‘s decision must include “a clear and satisfactory explication of the basis on which it rests” sufficient to enable a reviewing court “to perform its statutory function of judicial review.” Cotter, 642 F.2d at 704–05. Specifically, the ALJ must discuss the evidence that supports the decision, the evidence that the ALJ rejected, and explain why the ALJ accepted some evidence but rejected other evidence. Id. at 705–06; Diaz v. Comm‘r of Soc. Sec., 577 F.3d 500, 505–06 (3d Cir. 2009); Fargnoli v. Massanari, 247 F.3d 34, 42 (3d Cir. 2001) (“Although we do not expect the ALJ to make reference to every relevant treatment note in a case . . . we do expect the ALJ, as the factfinder, to consider and evaluate the medical evidence in the record consistent with his responsibilities under the regulations and case law.”). Without this explanation, “the reviewing court cannot tell if significant probative evidence was not credited or simply ignored.” Cotter, 642 F.2d at 705; see also Burnett, 220 F.3d at 121 (citing Cotter, 642 F.2d at 705).
The applicable regulation emphasizes that “the most important factors [that the ALJ and Commissioner] consider when [] evaluat[ing] the persuasiveness of medical opinions and prior administrative medical findings are supportability (paragraph (c)(1) of this section) and consistency (paragraph (c)(2) of this section).”
“Subjective allegations of pain or other symptoms cannot alone establish a disability.” Miller v. Comm‘r of Soc. Sec., 719 F. App‘x 130, 134 (3d Cir. 2017) (citing
In conducting this evaluation, an ALJ must consider the objective medical evidence as well as other evidence relevant to a claimant‘s subjective symptoms.
“Findings of fact by the [Commissioner] must be accepted as conclusive by a reviewing court if supported by substantial evidence.” Cotter v. Harris, 642 F.2d 700, 704 (3d Cir. 1981). Substantial evidence has been defined as “such relevant evidence as a reasoning mind might accept as adequate to support a conclusion.” Id. (citing Lewis v. Califano, 616 F.2d 73, 76 (3d Cir. 1980);
Plaintiff contends that in finding Plaintiff able to “handle and finger frequently” instead of only occasionally, the ALJ ignored Plaintiff‘s testimony that described greater limitations. Pl. Br. at 8. Plaintiff cites
Although the ALJ stated that Plaintiff‘s statements regarding the intensity, persistence and limiting effects of her symptoms were “not entirely consistent” with the record “for the reasons explained in this decision,” R. 15, nowhere in his determination does he connect this finding with respect to Plaintiff‘s carpal tunnel syndrome to evidence in the underlying medical records. Instead, in his RFC finding, the ALJ briefly summarizes the record, without reference to her hand limitations, and states in summary fashion: “Based on the foregoing, the undersigned finds the claimant has the above residual functional capacity assessment, which is supported by the evidence of record.” R. 17.
It is well established that an ALJ “‘cannot reject evidence for no reason or for the wrong reason.’” Masher v. Astrue, 354 Fed. Appx. 623, 627 (3d Cir. 2009) (quoting Plummer v. Apfel, 186 F.3d 422, 429 (3d Cir. 1999)). Evidence is not substantial if “‘it really constitutes not evidence but mere conclusion.’” Sutherland v. Comm‘r Soc. Sec., 785 F. App‘x 921, 927 (3d Cir. 2019) (quoting Kent, 710 F.2d at 114)). Importantly, “as part of the ALJ‘s duty of articulation, the ALJ must establish a logical bridge between the evidence and the ALJ‘s legal conclusions and factual findings.” Bienkowski v. Bisignano, No. 4:24-CV-1714, 2025 WL 1668328, at *7 (M.D. Pa. June 12, 2025).
The court in Koshir v. Kijakazi, No. CV 20-1441, 2022 WL 992529, at *4–6 (W.D. Pa. Mar. 31, 2022), illustrates the importance of this duty of articulation. In that case, the RFC “was actually quite extensive and specific.” Id. at *4. The ALJ “discussed the evidence generally in explaining how she determined the RFC,” but “at no point did she expressly indicate how she came to her specific determinations as to Plaintiff‘s functional limitations.” Id. at *4; see also id. at *3 (crafting a RFC for medium exertional work with multiple additional limitations, including, inter alia, “frequent handling and fingering with both hands”). The ALJ essentially “summarized the record evidence and then concluded, without any real explanation, that this evidence supported the RFC she crafted.” Id. The Koshir court found that it “is unable, simply by reviewing the ALJ‘s discussion of the evidence, to determine how that evidence translated into the very specific RFC findings made by the ALJ.” Id. at *5. The court specifically found that, as it related to the RFC limitation of frequent bilateral handling and fingering, the vocational expert testified that if the claimant “was limited to only occasional bilateral handling and fingering, he could not perform his past relevant work.” Id. (record citations omitted) (emphasis added). The court concluded that, because it “cannot determine the basis for the ALJ‘s finding limiting Plaintiff specifically to frequent fingering and handling, rather than to occasional, this distinction is potentially very relevant. The ALJ must more fully explain why the evidence supports her findings in this regard.” Id.; see also id. at *6 (stating that the court is “unable to review the ALJ‘s findings” where the ALJ does not build a logical bridge between the evidence and the ALJ‘s findings) (citations omitted).
Similarly, here, the ALJ‘s summary of the record does not satisfy his burden of articulation or sufficiently explain his basis for discounting Plaintiff‘s statements about her carpal tunnel symptoms; indeed, the ALJ‘s summary of the evidence barely reflects any mention of the medical findings with respect to Plaintiff‘s carpal tunnel syndrome diagnosis. R. 14–17. The ALJ noted Plaintiff testified at the hearing that she has, inter alia, carpal tunnel syndrome and that she has difficulty using her hands to wash dishes, does not use a computer at home, that her arms hurt when doing laundry, and can prepare a sandwich for lunch, but that her family members help with chores. R. 15. However, the ALJ failed to mention Plaintiff‘s testimony that,
The ALJ also referenced three physical examinations that addressed Plaintiff‘s carpal tunnel syndrome, but did not clarify why the ALJ found that Plaintiff could frequently—as opposed to occasionally—handle and finger, bilaterally. R. 16.7 The ALJ noted that in March 2023, at a time when Plaintiff was no longer working, she reported “some relief” from using Voltaren gel and wearing wrist braces, and “good relief” from Extra Strength Tylenol. Id. (citing Ex. 8F at 1; R. 459). However, the ALJ also noted that in April 2024, Plaintiff reported, inter alia, numbness and tingling in her arms, and she was diagnosed with carpal tunnel syndrome, id. (citing Ex. 8F at 17–18; R. 475–76), and that in July 2024, Plaintiff reported that her pain was worse with wrist flexion and pronation and, upon examination, there was tenderness and pain, id. (citing Ex. 9F at 1; R. 496).
The ALJ‘s failure to provide any basis in support of his finding that Plaintiff could do frequent fingering and handling required by her past relevant work, and for discounting Plaintiff‘s description of her job requirements and the extent of her pain, leaves the Court unable to determine what led the ALJ to this determination. Messina v. Comm‘r of Soc. Sec., 844 F. App‘x 586, 589–90 (3d Cir. 2021) (“Yet we cannot reweigh the evidence or make our own factual determinations.”) (citations omitted); Chandler v. Comm‘r of Soc. Sec., 667 F.3d 356, 359 (3d Cir. 2011) (“Courts are not permitted to reweigh the evidence or impose their own factual determinations [under the substantial evidence standard].” Despite acknowledging that her bilateral carpal tunnel syndrome was a “severe” impairment, that had “resulting limitations, which are reflected in the [RFC],” the ALJ failed to explain how he crafted Plaintiff‘s frequent (as opposed to occasional) hand-related limitations in the RFC. R. 13–17. The ALJ‘s decision therefore failed to provide a “logical bridge” between the evidence and his decision. See Bienkowski, 2025 WL 1668328, at *7; Glenda M. v. Comm‘r Soc. Sec., Civ. No. 22-03137, 2023 WL 6387515, at *6 (D.N.J. Sep. 29, 2023) (“An ALJ need not specifically address every piece of evidence, but must provide a ‘logical bridge’ between the evidence and [his] conclusions.”) (quoting O‘Connor-Spinner v. Astrue, 627 F.3d 614, 618 (7th Cir. 2010)).
As in Koshir, the ALJ‘s failure to explain the RFC limitation of frequent (instead of occasional) bilateral handling and fingering was not harmless error when viewed in light of the testimony of the vocational expert. See Koshir, 2022 WL 992529, at *4–6. When presented with the RFC proposed by the ALJ, the vocational expert asked the ALJ to confirm that the RFC
For these reasons, the Court REVERSES the Commissioner‘s decision and REMANDS the matter for further proceedings consistent with this Opinion and Order.
The Court will issue a separate Order issuing final judgment pursuant to Sentence 4 of
IT IS SO ORDERED.
Date: September 1, 2026
s/Cheryl L. Pollak
CHERYL L. POLLAK
UNITED STATES MAGISTRATE JUDGE