BERENS v. COMMISSIONER OF SOCIAL SECURITY

CourtDistrict Court, D. New Jersey
DecidedAugust 11, 2025
Docket2:24-cv-08566
StatusUnknown

This text of BERENS v. COMMISSIONER OF SOCIAL SECURITY (BERENS v. COMMISSIONER OF SOCIAL SECURITY) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BERENS v. COMMISSIONER OF SOCIAL SECURITY, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

: C.B., : Civil Action No. 24-8566 (SRC) : Plaintiff, : : OPINION v. : : COMMISSIONER OF : SOCIAL SECURITY, : Defendant. : : :

CHESLER, District Judge This matter comes before the Court on the appeal by Plaintiff C.B. (“Plaintiff”) of the final decision of the Commissioner of Social Security (“Commissioner”) determining that he was not disabled under the Social Security Act (the “Act”). This Court exercises jurisdiction pursuant to 42 U.S.C. § 405(g) and, having considered the submissions of the parties without oral argument, pursuant to L. CIV. R. 9.1(b), finds that the Commissioner’s decision will be vacated and remanded for further proceedings. In brief, this appeal arises from Plaintiff’s application for disability insurance benefits, alleging disability beginning July 1, 2020. A hearing was held before ALJ Lori Romeo (the “ALJ”) on June 21, 2023, and the ALJ issued an unfavorable decision on October 24, 2023. Plaintiff sought review of the decision from the Appeals Council. After the Appeals Council denied Plaintiff’s request for review, the ALJ’s decision became the Commissioner’s final decision, and Plaintiff filed this appeal.

1 In the decision of October 24, 2023, the ALJ found that, at step three, Plaintiff did not meet or equal any of the Listings. At step four, the ALJ found that Plaintiff retained the residual functional capacity to perform work at all exertional levels, with certain additional exertional and nonexertional limitations. At step four, the ALJ also found that Plaintiff has no past relevant work. At step five, the ALJ determined, based on the testimony of a vocational expert, that

there are jobs existing in significant numbers in the national economy which the claimant can perform, consistent with his medical impairments, age, education, past work experience, and residual functional capacity. The ALJ concluded that Plaintiff has not been disabled within the meaning of the Act. On appeal, Plaintiff argues that the Commissioner’s decision should be reversed and the case remanded with two arguments: 1) at step four, the ALJ failed to properly evaluate the persuasiveness of the opinions of Dr. Srinivasan and NP Marseille under 20 C.F.R. § 404.1520c; and 2) the RFC determination at step four does not meet the requirements stated by the Third Circuit in Hess. The Court finds that the ALJ’s decision does not contain sufficient explanation

to allow meaningful judicial review of the issues raised by Plaintiff’s Hess argument. Plaintiff argues that the ALJ’s decision does not meet the requirements stated by the Third Circuit in Hess v. Comm’r Soc. Sec., 931 F.3d 198, 210 (3d Cir. 2019). In Hess, the Third Circuit held: “as long as the ALJ offers a ‘valid explanation,’ a ‘simple tasks’ limitation is permitted after a finding that a claimant has ‘moderate’ difficulties in ‘concentration, persistence, or pace.’” Id. at 211. Plaintiff argues that, in the instant case, at step three, the ALJ determined that Plaintiff has moderate difficulties in “concentrating, persisting or maintaining pace” (Tr. 23), and, at step four, determined that Plaintiff retains the residual functional capacity to “understand,

2 remember, and carry out only simple instructions” (Tr. 23). Plaintiff contends that the facts of this case are similar enough to those of Hess that the holding of Hess applies, and that the ALJ was therefore required to provide a valid explanation for the “simple instructions” limitation in the RFC. Hess, 931 F.3d at 211. In opposition, the Commissioner agrees that Hess applies to this case, but argues that the ALJ provided the valid explanation required by Hess.

In short, this Court finds that the ALJ’s decision does not contain sufficient explanation or development of the record to permit meaningful judicial review to determine whether or not the requirements of Hess have been satisfied. In Hess, the district court had reversed the ALJ’s decision, but the Third Circuit held that the district court had erred, largely because “it is essential to assess whether a valid explanation has been given for an ALJ’s statement of a claimant's limitation to ‘simple tasks.’” Id. at 213. The Third Circuit made this assessment, addressing the question of whether or not the ALJ’s decision provided a valid explanation for using a “simple tasks” limitation in the RFC after finding moderate difficulties in “concentration, persistence, or pace” at step three. Id. at 211. The Third Circuit explained its principal concern

as follows: In short, the functional limitation findings [found at step three] do not dictate the terms of the ALJ's statement of the claimant's limitation in the final analytical steps. But those findings are relevant to that statement of the limitation, which must be sufficient to reflect all of a claimant's impairments.

Id. at 210 (italics added). This is the concern that animates the “valid explanation” inquiry: the ALJ must provide the basis for determining that the limitation in the RFC formulation sufficiently reflects the full scope of the claimant’s impairments in concentration, persistence, or pace. In Hess, the Third Circuit examined the ALJ’s decision and applied this inquiry, and, in

3 short, found that “the ALJ explained at length and with sound reasoning why Hess's ‘moderate’ difficulties in ‘concentration, persistence, or pace’ were not so significant that Hess was incapable of performing ‘simple tasks.’” Id. at 213. In other words, the Third Circuit found a valid explanation where the ALJ had explained the basis for the conclusion that the limitation in the RFC (“simple tasks”) sufficiently reflected the claimant’s difficulties with concentration,

persistence, or pace. In the instant case, the ALJ did not use a “simple tasks” limitation in the RFC, but instead wrote: “Additionally, claimant can understand, remember, and carry out only simple instructions.” (Tr. 23.) The question for this Court then, applying the Hess inquiry, is whether the ALJ explained why this limitation to work with simple instructions sufficiently reflects the full scope of the moderate difficulties in concentration, persistence, or pace that were found at step three. The Court finds that it is not presently able to resolve the parties’ dispute regarding Hess because the ALJ did not sufficiently explain her findings at step three. In essence, the Hess

inquiry asks the Court to look to the finding of moderate difficulties in concentration, persistence, or pace at step three, and then to check that the limitations in the RFC are “sufficient to reflect all of a claimant’s impairments.” To perform this task, the Court needs to ascertain what exactly the ALJ found at step three. At step three, here is the ALJ’s entire statement on this subject: With regard to concentrating, persisting or maintaining pace, the claimant has a moderate limitation. Through his counsel, claimant asserted that he is unable to make simple work-related decisions (Exhibit 14E at 2). There is evidence of marginal reading, writing and math skills, but claimant works at a restaurant as a greeter two days per week and drives himself to work (Hearing testimony). Also, upon testing claimant was oriented in three spheres. He could spell words forward but not backward and perform simple counting. Mr. Berens recalled four digits forward on the first trial and was not able to perform the task of digit span

4 backwards. Mr.

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BERENS v. COMMISSIONER OF SOCIAL SECURITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/berens-v-commissioner-of-social-security-njd-2025.