Unreported / Non-Citable
Background
Jesse Cardenas Martinez sought judicial review of the Social Security Commissioner's final decision denying his applications for disability insurance benefits and supplemental security income under the Social Security Act. Martinez alleged he became disabled on November 20, 2019, citing a seizure disorder, left lomonymous meianopsia, anxiety, and depression. After the Commissioner denied the applications initially on January 6, 2021, and on reconsideration on November 30, 2021, Martinez requested a hearing, and an Administrative Law Judge conducted a hearing on June 4, 2024, at which Martinez testified with counsel and Medical Expert psychiatrist Dr. Aminian also testified. In a decision dated July 26, 2024, the ALJ found Martinez not disabled under the five-step sequential analysis in 20 C.F.R. § 404.1520.
At step two, the ALJ found Martinez's impairments severe. At step three, the ALJ determined he did not have an impairment or combination of impairments meeting or medically equaling a listed impairment, rating him moderately limited in his ability to interact with others and markedly limited in his ability to concentrate, persist, or maintain pace. The ALJ assessed a residual functional capacity for light work with physical restrictions, limited to non-complex jobs requiring no more than simple, routine tasks, with only occasional contact with co-workers and the public. The ALJ found Martinez could not perform his past relevant work but, relying on Vocational Expert testimony, could perform jobs such as office clerk, mail clerk, and shipping and receiving weigher. The Appeals Council denied review on August 22, 2025, making the ALJ's decision the Commissioner's final decision.
The Court’s Holding
The court affirmed the Commissioner's decision. Martinez asserted a single claim of error: that the ALJ's decision was internally inconsistent because the ALJ found a marked limitation in concentration, persistence, or pace at step three but failed to include a corresponding accommodation in the RFC. The court agreed with Martinez that the ALJ was required to translate any limitation, even one stemming from a non-severe impairment, into the RFC. Although SSR 96-8P states that the paragraph B and C criteria are severity ratings rather than an RFC assessment, the same ruling and agency regulations require an ALJ to consider the functional effects of all impairments, even non-severe ones, when formulating the RFC.
The court nevertheless agreed with the Commissioner that the assessed RFC sufficiently accounted for the limitation. The ALJ credited Dr. Aminian's testimony that doing complex work was not appropriate for Martinez when anxious, and that same testimony supported the marked step-three finding. The court rejected Martinez's argument that crediting an opinion that he could not complete complex tasks was necessarily work-preclusive: an inability to complete complex tasks does not preclude simple, routine work. Because the marked limitation rested exclusively on the opinion that complex work was not appropriate, limiting Martinez to non-complex or simple work sufficiently accounted for the deficit, and the RFC was supported by substantial evidence.
Key Takeaways
- An ALJ must incorporate into the residual functional capacity assessment all functional limitations caused by medically determinable impairments, even non-severe ones identified through the Psychiatric Review Technique at steps two and three.
- A marked step-three limitation in concentration, persistence, or pace does not automatically render a simple-task RFC inadequate or require a disability finding.
- Where that marked limitation is based exclusively on a medical opinion that complex work is not appropriate, a limitation to non-complex or simple work can sufficiently account for the deficit.
- An inability to complete complex tasks is not necessarily work-preclusive and does not bar a finding that the claimant can perform simple, routine tasks.
- A court will uphold an ALJ's RFC as supported by substantial evidence when it adequately translates credited medical opinions into specific functional limitations.
Why It Matters
The decision clarifies how step-three paragraph B severity findings interact with the more detailed residual functional capacity assessment at steps four and five. ALJs must consider all limitations, including those from non-severe impairments, but a simple or non-complex work limitation may capture a marked concentration, persistence, or pace limitation when that limitation rests solely on an opinion that complex work is not appropriate. The ruling reinforces that the RFC requires a function-by-function analysis more detailed than the step-three categories, and that not every marked step-three rating translates into a work-preclusive restriction.