Reported / Citable
Background
Alicia Ann King, age 52 with a high school diploma and some college courses, applied for Social Security Disability Insurance Benefits on February 15, 2023, claiming disability onset on September 23, 2021. After denial of her initial claim and request for reconsideration, King requested a hearing before Administrative Law Judge Alexis Murdock on January 24, 2025. The ALJ issued a decision on February 19, 2025 finding that King was not disabled. Following the Appeals Council’s denial of review, King brought this action in federal court.
The ALJ found that King had severe impairments including lumbar degenerative disc disease, plantar fasciitis, left ankle and knee osteoarthritis, tendinitis, obesity, depression, insomnia, generalized anxiety disorder, and post-traumatic stress disorder. At step three of the sequential evaluation, the ALJ determined these impairments did not meet or medically equal the Social Security Listings. The ALJ found King retained residual functional capacity for light work with limitations: she could understand, remember, and carry out detailed but not complex instructions; and could interact frequently with supervisors and coworkers but only occasionally with the public. Based on vocational expert testimony identifying three jobs King could perform (merchandise marker with 165,000 jobs, assembler with 28,000 jobs, and routing clerk with 23,000 jobs), the ALJ concluded at step five that King was not disabled.
The Court’s Holding
The Magistrate Judge recommended affirming the Commissioner’s denial of benefits. On King’s first argument—that the residual functional capacity findings were inconsistent with the ALJ’s step-two findings of severe mental impairments—the court rejected her contention that a severe mental impairment finding necessarily requires specific limitations on the ability to understand and carry out simple instructions. Citing Wells v. Saul (S.D. Tex. 2021) and Roberts v. Comm’r of Social Security (N.D. Tex. 2025), the court held that findings at step two do not require word-for-word incorporation into later RFC determinations, as different legal standards apply at each step. The ALJ properly connected her findings of moderate limitations in concentration, persistence, and pace—as well as in interacting with others—to the RFC restrictions limiting King to detailed (not complex) instructions and occasional (not frequent) public interaction.
On King’s second argument regarding allegedly obsolete occupations, the court acknowledged concerns about whether merchandise marker positions realistically exist in significant numbers given modern barcode technology. However, substantial evidence supported the vocational expert’s testimony. The expert cited reliable sources including Job Browser Pro, Bureau of Labor Statistics, U.S. Census data, and professional journals. King’s counsel neither challenged the VE’s sources nor questioned her credentials at the hearing. Even if marker jobs were reduced by half to 82,500, that number would remain significant. Additionally, 28,000 assembler jobs—unchallenged—provided sufficient alternative employment.
Key Takeaways
- ALJs have flexibility in translating step-two severe impairment findings into RFC limitations; different legal standards apply at each step of the sequential evaluation process
- Moderate mental limitations in concentration and social interaction can be adequately addressed through RFC restrictions on task complexity and frequency of public contact
- Vocational expert testimony based on reliable data sources and unchallenged expertise provides substantial evidence, even when the occupations raise modern concerns about technological obsolescence
- Courts will not second-guess evidentiary choices or medical findings without evidence that no credible evidentiary choice supports the ALJ’s decision
Why It Matters
This decision clarifies how the five-step disability evaluation process operates—specifically that findings at one step do not automatically dictate rigid corresponding findings at later steps. For claimants with mental health conditions, this ruling establishes that ALJs need not make identical or parallel findings across the sequential steps, provided substantial evidence connects the mental impairment findings to the RFC limitations. The decision will likely influence how disability cases involving mental impairments proceed in the Fifth Circuit.
The opinion also addresses the evolving challenge of occupational obsolescence in disability cases. While judges may harbor doubts about whether jobs like merchandise marker remain viable in a barcode-scanning world, the court held that absent effective challenge to the expert’s sources or methodology at the hearing level, judicial skepticism alone does not undermine substantial evidence. This may become increasingly significant as technological change renders traditional occupational classifications outdated.