## Facts

- Ethel Burnett, born in 1935 with a tenth-grade education, worked in supermarket meat and delicatessen departments from 1977 to 1991.
- In December 1989, Burnett slipped and fell at work, injuring her right knee and lower back.
- Treating and consulting physicians noted knee tenderness, minor swelling, muscle weakness, and an antalgic gait; imaging showed slight joint narrowing and effusion; she was diagnosed with chondromalacia and treated with medication and physical therapy.
- Physical therapy records indicated improvement and a return to work by March 1990, though she continued to report knee symptoms.
- In 1991, she reported back pain; MRI showed first-degree spondylolisthesis at L5-S1 without significant spinal stenosis.
- Burnett alleged she became unable to work as of May 18, 1991.
- Burnett and her husband submitted statements describing significant limitations from pain, including difficulty standing or sitting for extended periods, sleep problems, and reliance on pain medication.
- In January 1992, Burnett applied for Title II disability insurance benefits.

## Issues

1. Whether the ALJ’s step-three finding that Burnett’s impairments did not meet or equal a listed impairment was legally sufficient without identifying relevant listings or explaining how the evidence failed to satisfy them.
2. Whether the ALJ adequately evaluated and explained the weight given to Burnett’s subjective pain complaints and corroborating lay testimony, including her husband’s statement.

## Decision

- The Third Circuit vacated the district court’s judgment affirming the denial of benefits and remanded with instructions to return the matter to the Commissioner for further proceedings.
- The court held the ALJ’s decision was legally insufficient because it did not provide an explanation at step three that allowed judicial review.
- The court also held the ALJ did not adequately explain the evaluation of Burnett’s pain allegations and supporting lay evidence.

## Legal Principles

- An ALJ must provide enough reasoning to permit meaningful judicial review; a reviewing court cannot uphold an administrative decision based on rationales the ALJ did not state.
- At step three, an ALJ must do more than announce a conclusion that no listing is met or equaled; the ALJ must discuss the evidence and explain the basis for the listing determination.
- In weighing evidence, the ALJ must consider all relevant evidence, indicate what evidence is credited or rejected, and provide reasons for rejecting material evidence, including subjective complaints and lay statements.
- The substantial-evidence standard presupposes an adequately explained decision; conclusory findings prevent a court from determining whether substantial evidence supports the result.

## Conclusion

Because the ALJ’s listing analysis and treatment of pain and lay evidence were too conclusory to permit judicial review, the Third Circuit vacated and remanded for a properly explained step-three determination and an articulated evaluation of the relevant evidence.


Burnett v. Comm’r of Soc. Sec. Admin., 220 F.3d 112 (3d Cir. 2000)