## Facts

- Eugene Gabriel had his left leg amputated after osteosarcoma diagnosed nearly 30 years before he applied for Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI).
- Gabriel used a prosthetic leg, but extended wear caused blisters on his stump that could bleed, requiring ongoing stump care and periodic limits on prosthesis use.
- Because of these complications, Gabriel needed flexible work arrangements and job accommodations.
- When he applied for benefits, Gabriel worked part time at a grocery store, limiting his schedule to four hours per day and no more than two consecutive workdays so he could care for his stump.
- An Administrative Law Judge (ALJ) found Gabriel’s amputation was a “severe” impairment but concluded it did not meet or medically equal a listed impairment in 20 C.F.R. Part 404, Subpart P, Appendix 1.
- The ALJ also found Gabriel had the residual functional capacity (RFC) to perform sedentary work and that, considering his age, education, and work experience, there were a significant number of jobs he could perform.
- The ALJ’s written decision stated these conclusions without providing supporting findings or analysis connecting the evidence to the Listings determination or to the RFC and step-five conclusions.
- After the agency denied benefits, Gabriel sought judicial review in federal district court under 42 U.S.C. § 405(g), challenging (among other points) the lack of explanation in the ALJ’s Listings and RFC determinations.

## Issues

1. Whether an ALJ’s conclusory statement that a claimant’s severe impairment does not meet or medically equal a listed impairment is legally sufficient when the decision contains no supporting findings or analysis.
2. Whether an ALJ’s RFC and step-five findings (including the conclusion that the claimant can perform sedentary work and that significant jobs exist) can stand when the decision provides no explanation linking the record evidence to those conclusions.
3. Whether the absence of articulated reasoning prevents judicial review under 42 U.S.C. § 405(g) and requires remand for further administrative proceedings.

## Decision

- The district court remanded the case to the Commissioner for further proceedings.
- The court concluded the ALJ’s decision was deficient because it provided no findings or analysis to support key determinations, including the step-three Listings conclusion and the RFC/step-five conclusions.
- Because the ALJ did not explain how the evidence supported the outcome, the court could not evaluate whether the decision was supported by substantial evidence as required by § 405(g).

## Legal Principles

- Under 42 U.S.C. § 405(g), a federal court reviews whether the Commissioner applied the correct legal standards and whether the final decision is supported by substantial evidence.
- Although the claimant bears the burden at step three to show that an impairment meets or medically equals a listed impairment, the ALJ must still provide enough explanation to permit a reviewing court to evaluate the step-three conclusion.
- A bare or conclusory step-three finding—without identifying the factual basis for concluding that the Listing criteria are not met or equaled—can be inadequate because it blocks judicial review.
- RFC and step-five findings must be explained with reference to the evidence; an ALJ must do more than announce conclusions (such as “sedentary work” or “significant number of jobs”) without stating how the claimant’s documented limitations were weighed and resolved.
- When an ALJ fails to provide supporting findings and reasoning on dispositive points, the proper remedy is generally remand for a reasoned decision rather than affirmance based on post hoc rationales.

## Conclusion

Gabriel v. Astrue held that the ALJ’s denial of SSDI and SSI could not be affirmed where the decision offered conclusions—at step three and in the sedentary RFC/step-five analysis—without supporting findings or reasoning, leaving the court unable to determine whether substantial evidence supported the denial; the case was remanded for further explanation and proceedings.


Gabriel v. Astrue, 2009 WL 453372 (2009)