ROONEY

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA

PITTSBURGH DIVISION

TAMMY M. ROONEY, ) Civil Action No. 2:24-CV-01692-CBB

)

)

Plaintiff, )

) United States Magistrate Judge

vs. ) Christopher B. Brown

)

FRANK BISIGNANO,1 )

COMMISSIONER, SOCIAL )

)

SECURITY ADMINISTRATION, )

Defendant,

MEMORANDUM OPINION2

ON PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT, ECF NO. 11

I. Introduction

Plaintiff Tammy Rooney filed her claim for Disability Insurance Benefits

under Title II of the Social Security Act (the “Act”), 42 U.S.C. §§ 401–434, on August

9, 2022. ECF No. 12 at 1. Specifically, Rooney claimed that she became disabled

beginning July 8, 2022 due to gastroparesis, hypertension, arthritis, irritable bowel

syndrome, generalized anxiety disorder, major depressive disorder, panic disorder,

and a blood clot in the right leg. Id.

1 Frank Bisignano is substituted as the Defendant in this matter, pursuant to Federal Rule of

Civil Procedure 25(d) and 42 U.S.C. § 405(g). The Clerk is directed to amend the docket to reflect

this change.

2 All parties have consented to jurisdiction before a United States Magistrate Judge; therefore

the Court has the authority to decide dispositive motions, and to eventually enter final judgment.

See 28 U.S.C. § 636, et seq.

Rooney’s claims were denied initially and then again on reconsideration.

ECF No. 3-2 at 11. She sought a hearing before an Administrative Law Judge

(“ALJ”) on December 8, 2023. Id. In a March 6, 2024 decision, the ALJ denied

Rooney’s request for benefits and found that Rooney was not disabled under the Act.

Id. The Appeals Council declined to review the ALJ's decision on October 29, 2024.

ECF No. 3-2 at 2. On December 13, 2024, Plaintiff filed a timely appeal with this

Court and filed a motion for summary judgment. ECF No. 1.

Rooney’s motion for summary judgment is fully briefed and ripe for

consideration. ECF Nos. 11-12, 16-17. As set forth in more detail below, Rooney’s

motion is DENIED. The decision of the ALJ will be AFFIRMED.

II. Factual Background

The following summary is limited to information relevant to the current

appeal. Rooney was 50 years old at the onset of her alleged disability on July 8,

2022. ECF No. 3-2 at 23. She had previously worked as a cake decorator but

testified that she stopped working because of the amount of bathroom breaks

caused by her irritable bowel disease. Id. at 23, 50-51. Rooney also has anxiety and

depression, and works with a licensed clinical social worker, Michelle Braun, and a

physician’s assistant Geena Edmonds. Id. at 16, 19. Rooney is in a custody dispute

and seeking custody of her grandchildren. Id. at 19.

Among other medical testimony, there are four key psychological opinions

and one psychological evaluation in the present record. In a January 24, 2023

psychological consultation with psychologist Gina Lombardi, Rooney complained of

waking in the middle of the night, sad moods, crying spells, loss of interest,

irritability, agitation, fatigue, concentration problems, social withdrawal, worry,

restlessness, difficulty concentrating, and avoidance of social settings. ECF No. 3-8

at 63. Lombardi opined that, among other things, Rooney had a “marked”

limitation in her ability to understand, remember, and carry out complex

instructions and interact appropriately with supervisors and co-workers. Id. at 66-

67. Lombardi also opined that Rooney had a “moderate” limitation on her ability to

make judgments on simple work-related decisions and interact appropriately with

the public, and “mild” limitations on her ability to understand, remember, and carry

out simple instructions. Id. She did not provide a specific limitation on Rooney’s

abilities related to concentration, persistence, and pace. Id.

Rooney’s treating mental health provider, Michelle Braun, also provided an

opinion form regarding Rooney’s psychological condition. Braun began seeing

Rooney in 2022 for an adjustment disorder with anxiety and depression. Id. at 134.

Braun opined that Rooney was not limited in her ability to concentrate, persist, or

maintain pace and that she would be able to maintain concentration for one hour

before needing redirection or a break. Id. at 136-38.

Geena Edmonds – a physician’s assistant who treated Rooney for her mental

health concerns – evaluated her on February 10, 2023. Id. at 77-79. Edmonds

stated in the evaluation that Rooney had normal attention, concentration, short and

long term memory, and reasoning, and was able to do simple calculations and serial

sevens. Id. Rooney visited Edmonds again in March, May, and June 2023 but there

were no other clinical notes available. Id. at 140.

Two state agency psychologists also provided opinions. The state agency

psychologists said that Rooney had “severe” mental impairments. ECF No. 3-3 at 5;

16. They found Rooney had “moderate” limitations in concentrating, persisting, or

maintaining pace, and “mild” limitations in the other areas of mental abilities. ECF

Id. The state psychologists opined that Rooney could perform one to two-step tasks

and could understand, retain, and follow simple job instructions. Id. at 9; 21.

III. The ALJ Decision

The following summary is limited to information relevant to the current

appeal. At step one of the sequential analysis, the ALJ found Rooney had not

engaged in substantial gainful activity since her alleged disability onset date. ECF

No. 3-2 at 14. At step two, the ALJ found Rooney had multiple severe impairments

including anxiety and depression, diverticulosis, irritable bowel syndrome,

gastroesophageal reflux disease, obesity, gastroparesis, hypertension, bilateral

venous insufficiency, superficial thrombophlebitis, and degenerative disc disease of

the lumbar spine. Id. At step three, the ALJ found Rooney did not have an

impairment or combination of impairments that met or equaled a listed impairment

in 20 C.F.R. pt. 404, subpt. P, app. 1. Id. at 15. In relevant part, the ALJ also

found that Rooney has “moderate” limitation in concentration, persistence, and

pace. Id. at 16.

At step four, the ALJ then found Rooney has the residual functional capacity

(“RFC”) to perform light work as defined in 20 CFR 404.1567(b). Id. at 17. Among

other physical limitations, the RFC also included three mental limitations:

• Only simple, routine tasks involving simple work-related decisions;

• Occasional interaction with coworkers and supervisors, and no

interaction with the public and

• Few changes to work process and setting

Id.

Relying on the RFC, the ALJ found Rooney could not perform her past

relevant work. Id. at 23. At step five and relying on the testimony of the

Vocational Expert, the ALJ found Rooney could perform several jobs that exist in

significant numbers in the national economy, including the representative

occupations of bottle packer, a marker, and a mail sorter. Id. at 24. Each of the

jobs identified by the Vocational Expert have a reasoning level of 2 or 3 as defined

by the Dictionary of Occupational Titles (“DOT”). See DOT definitions bottle packer

(DOT code: 920.685-026, reasoning 2); marker (DOT code: 209.587-034, reasoning

2); mail sorter (DOT code: 209.687-026, reasoning 3). The ALJ then found that

Rooney was not disabled. Id.at 25.

IV. Standard of Review

Judicial review of a social security case is based upon the pleadings and the

transcript of the record, and the scope of that review is limited to determining

whether the Commissioner applied the correct legal standards and whether the

record, as a whole, contains substantial evidence to support the Commissioner's

findings of fact. See 42 U.S.C. § 405(g). If the Court finds substantial evidence

supports the final decision, it must uphold it. See Rutherford v. Barnhart, 399 F.3d

546, 552 (3d Cir. 2005). The Court may not set aside a decision that is supported by

substantial evidence “even if [it] would have decided the factual inquiry differently.”

Hartranft v. Apfel, 181 F.3d 358, 360 (3d Cir. 1999) (citing § 405(g)).

“Substantial evidence” is defined as “more than a mere scintilla.” Plummer v.

Apfel, 186 F.3d 422, 427 (3d Cir. 1999). It means “such relevant evidence as a

reasonable mind might accept as adequate” to support a conclusion. Id.; Biestek v.

Berryhill, 139 S. Ct. 1148, 1154 (2019). An ALJ's findings must “be accompanied by

a clear and satisfactory explication of the basis on which [they] rest[ ].” Cotter v.

Harris, 642 F.2d 700, 704 (3d Cir. 1981). Decisions that are conclusory in their

findings or indicate the ALJ's failure to consider all the evidence are not supported

by substantial evidence. See id. at 705-06. Moreover, the Court must ensure the

ALJ did not “reject evidence for no reason or for the wrong reason.” Id. at 706

(citing King v. Califano, 615 F.2d 1018 (4th Cir. 1980)).

To be eligible for Social Security benefits under the Act, a claimant must

demonstrate that they cannot engage in “substantial gainful activity” because of a

medically determinable physical or mental impairment which can be expected to

result in death, or which has lasted or can be expected to last for a continuous

period of at least twelve months. 42 U.S.C. § 423(d)(1)(A); Brewster v. Heckler, 786

F.2d 581, 583 (3d Cir. 1986).

When reviewing a claim, the ALJ must utilize a five-step sequential analysis

to evaluate whether a claimant has met the requirements for disability. 20 C.F.R.

§§ 404.1520, 416.920. The ALJ must determine:

(1) whether the claimant is currently engaged in substantial gainful activity;

(2) if not, whether the claimant has a severe impairment or a combination of

impairments that is severe;

(3) whether the medical evidence of the claimant's impairment or

combination of impairments meets or equals the criteria listed in 20 C.F.R.,

Pt. 404, Subpt. P, App. 1;

(4) whether the claimant's impairments prevent them from performing their

past relevant work; and

(5) if the claimant is incapable of performing their past relevant work,

whether they can perform any other work which exists in the national

economy.

20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); see Barnhart v. Thomas, 540 U.S. 20, 24–

25 (2003). If the claimant is determined to be unable to resume previous

employment, the burden shifts to the Commissioner at Step 5 to prove that, given

claimant's mental or physical limitations, age, education, and work experience, they

can perform substantial gainful activity in jobs available in the national economy.

Doak v. Heckler, 790 F.2d 26, 28 (3d Cir. 1986).

V. Discussion and Analysis

Rooney’s appeal focuses on the mental limitation in the RFC limiting her to

“[o]nly simple, routine tasks involving simple work-related decisions.” ECF No. 12

at 8. Rooney argues the ALJ’s RC determination is the product of legal error and is

“not properly reconciled with the evidence and the opinions of record [the ALJ]

determined were generally persuasive.” Id. at 1.

Rooney makes three arguments:

1) the ALJ provided no explanation as to how “simple, routine tasks”

would accommodate Rooney’s mental impairments;

2) the RCF does not incorporate the one-to-two step limitations from

the state agency psychologists’ opinions; and

3) the RFC’s limitation to limitation to “simple, routine tasks”

conflicts with the jobs identified by the Vocational Expert with

reasoning levels 2-3.

Id. at 8-13. These are addressed in turn.

a. The ALJ provided an adequate explanation as to how the

“simple, routine tasks” limitation accommodates Rooney’s

mental impairments

Rooney’s first argument focuses on limitations to concentration, persistence,

and pace in the RFC. Rooney argues the ALJ runs afoul of Third Circuit Court of

Appeals precedent under Hess v. Comm'r Soc. Sec., 931 F.3d 198, 211 (3d Cir. 2019)

(requiring a “valid explanation” for why an ALJ limits a person to “simple tasks”

when they have a moderate limitation in concentration, persistence, and pace).

ECF No. 12 at 10. Rooney argues that the ALJ did not offer an explanation “as to

how or why simple and routine tasks would accommodate Plaintiff’s impairments”

after finding she had a “moderate limitation” in concentration, persistence, and

pace. Id. Rooney further argues the “RFC does not truly account for the limitations

identified by either physician as there is no limitation within the RFC that accounts

for the moderate limitation in concentration.” Id.

The Commissioner responds that the ALJ adequately explained her decision-

making under the standards set forth in Hess because the ALJ cited “ample

evidence to support her finding that Plaintiff retained the mental capacity to

perform ‘simple and routine’ tasks.” ECF No. 16 at 11. The Commissioner further

argues that the ALJ indeed provided a valid explanation for her limitation on

simple and routine tasks by “highlighting factors such as Plaintiff’s adequate

functioning during mental status examinations, her well-controlled symptoms on

medication, and her performance of simple daily activities.” ECF No. 16 at 11.

Cited by both parties, the Third Circuit Court of Appeals in Hess dealt with

the same question currently before the Court – whether an RFC limiting a claimant

to “simple tasks” adequately addresses moderate limitations on concentration,

persistence, and pace. Hess, 931 F.3d at 211. The Hess Court held that as long as

an ALJ “offers a valid explanation” for why they limited someone with moderate

difficulties in concentration, persistence, or pace to “simple tasks,” then the RFC

adequately accounts for moderate limitations in concentration and the ALJ’s finding

should be affirmed. Id. The Court indicated that an ALJ offers a valid explanation

when they consider “mental status examinations and reports that revealed that [the

plaintiff] could function effectively; opinion evidence showing that [the plaintiff]

could do simple work; and [the plaintiff]'s activities of daily living, which

demonstrated that [s]he is capable of engaging in a diverse array of ‘simple tasks.”

Id. at 214.

Here, the ALJ addressed the criteria from Hess and offered a valid

explanation for how a limitation to “simple, routine” tasks adequately accounted for

Rooney’s difficulties with concentration, persistence, and pace. , the ALJ

explained what factors she considered when determining the RFC mental criteria,

finding that Rooney’s “mental impairments were generally well-managed through

outpatient therapy and medication during the relevant period, despite situational

stressors,” and that she had “very limited treatment with her psychiatric providers,”

Michelle Braun and Geena Edmonds. ECF No. 3-2 at 19-20. The ALJ further

explained she “incorporated various mental limitations” into the RFC to

“accommodate her challenges (including, limited to simple, routine tasks involving

simple work- related decisions; occasional interaction with supervisors and

coworkers, but no interaction with the general public; and able to tolerate few

changes to work process and setting).” Id. at 20.

, as it comes to concentrating, persisting, or maintaining pace

specifically, the ALJ considered the Hess criteria, including the mental status

examinations, opinion evidence, and the plaintiff’s activities of daily living, all of

which demonstrated her ability to complete simple tasks. The ALJ specifically

looked at Rooney’s February 10, 2023 psychiatric evaluation which “reflected

normal findings as to attention and concentration, long-term and short-term

memory, reasoning, simple calculations and serial sevens, and a normal fund of

knowledge.” Id. at 16. The ALJ then noted that the Plaintiff reported “daily

activities that include watching television and crocheting, which both inherently

require concentration and attention for extended periods of time.” Id. at 16. The

ALJ also noted that “[w]hile [Plaintiff] reports challenges with completing tasks and

concentration, especially with situational stressors, she has been involved in high

stress situations,” and that Rooney “reported that that she finishes the activities

she starts (unless she has a panic attack or abdominal pain), and follows

instructions well).” Id. at 16, 18.

, the ALJ found that Rooney is able to complete simple tasks because

she “demonstrated the ability to manage her mental impairments in a complex

situation, specifically involving the custody battle and actively seeking custody of

her young grandchildren.” Id. at 19. The ALJ also found that Rooney is

“independent with all of her personal care, performs household tasks, and takes

care of her cats on a daily basis, as well as her grandchildren on occasion (while

babysitting),” and is able to drive a vehicle and shop outside of her home. Id. at 15.

The ALJ’s analysis here is similar to recent cases in this Circuit where

Courts found an ALJ offered a valid explanation for their decision. For example, in

Weaver v. Saul, the Court upheld an ALJ’s decision where the ALJ explained the

plaintiff “regularly engaged in various activities that require concentration,

persistence, or pace,” that she had “normal intact concentration, attention, and

memory,” and where the ALJ examined the plaintiff’s testimony, aunt’s testimony,

and the function report submitted by the plaintiff’s mother. Weaver v. Saul, CV 18-

3295, 2019 WL 4220927, at *1 (E.D. Pa. Sept. 5, 2019). See also Tharp v. Bisignano,

No. 4:24-CV-200, 2025 WL 2472240, at *11 (M.D. Pa. Aug. 27, 2025) (“In the instant

case the ALJ fulfilled this duty by crafting an RFC based upon what were the more

persuasive and timely medical opinions. Substantial evidence supported the ALJ's

conclusions in this regard. Thus, there was no error here”); Sensenig v. Dudek, No.

3:24-CV-00170, 2025 WL 896452, at *13 (M.D. Pa. Mar. 24, 2025) (“Relying upon

expert opinions, and considering [plaintiff’s] activities of daily living, as well as the

overall clinical record, the ALJ found that the plaintiff could perform simple

tasks.”); Gilbert v. Kijakazi, No. 1:21-1493, 2022 WL 18396429, at *12 (M.D. Pa.

Nov. 29, 2022), report and recommendation adopted, No. 1:21-1493, 2022 WL

17730879 (M.D. Pa. Dec. 16, 2022) (“[T]he ALJ has offered a valid explanation for

this mental RFC, an explanation which draws substantial support from the clinical

and medical opinion record”).

The ALJ thoroughly recited the evidence in this case and supported her

limitation of “simple, routine jobs” with valid evidence. The RFC therefore properly

accounted for Rooney’s difficulties in concentrating, persisting, and maintain pace.

Accordingly, the ALJ’s decision is upheld.

b. The ALJ did not commit legal error by omitting one and two

step task limitations from the RFC

Rooney also argues the ALJ committed legal error because the ALJ did not

incorporate a limitation on one and two step tasks into the RFC, as suggested by

the state psychologists, and did not provide a logical explanation for the omission.

ECF No. 12 at 9. More specifically, Rooney argues that it appears the ALJ intended

to base the mental RFC on the state agency psychologists’ opinions but instead

omitted one of their key opinions without an explanation – that the plaintiff be

limited to one to two step tasks. Id. In opposition, the Commissioner argues

“[t]here is no categorical rule requiring an ALJ to adopt, or explicitly reject, every

feature of a medical opinion that the ALJ discussed and found generally or

somewhat persuasive,” and that the ALJ cited ample evidence to support her

mental capacity finding. ECF No. 16 at 10-11. Rooney replies that even if the ALJ

was not required to adopt every finding by the state psychologist, the ALJ still did

not offer any explanation about why she omitted the one and two step tasks

limitation even when she found the opinions persuasive. ECF No. 17 at 2. Rooney’s

argument is not persuasive.

The Court finds the ALJ did not commit a legal error in choosing to omit the

one and two step tasks limitation from the RFC. Here, the ALJ was only “generally

persuaded” by the opinions of the two state psychologists and instead modified the

RFC based on Rooney’s testimony. ECF No. 3-2 at 20. Where an ALJ finds a

medical opinion only “generally persuasive,” an ALJ is “under no obligation to adopt

all of the limitations to which these doctors opined,” including a limitation to one

and two step tasks. Reichenbach v. Comm'r of Soc. Sec., No. CV 23-1100, 2024 WL

4336301, at *1 (W.D. Pa. Sept. 26, 2024) (finding no obligation to incorporate one to

two steps tasks where the opinion is only “generally persuasive”). The ALJ was not

required to incorporate the one and two step tasks limitation into the RFC even

though it was recommended by the state psychologists.

The ALJ also did not err in omitting an explanation of this decision in her

findings. As the Commissioner points out, the ALJ does not have to incorporate

every finding in a persuasive medical opinion or “explicitly reject any part of a

persuasive opinion that does not make it into the RFC.” Rentz v. Bisignano, No. CV

24-1293, 2025 WL 2522379, at *1 (W.D. Pa. Sept. 2, 2025). See also Wilkinson v.

Comm'r of Soc. Sec., 558 Fed. Appx 254, 256 (3d Cir. 2014) (stating “[a]s an initial

matter, no rule or regulation compels an ALJ to incorporate into an RFC every

finding made by a medical source simply because the ALJ gives the source's opinion

as a whole ‘significant’ weight”). The ALJ was not required to explain the omission

since she otherwise supported her limitation of simple tasks, as explained above.

See § V(a), supra. See also Rentz v. Bisignano, No. CV 24-1293, 2025 WL 2522379,

at *1 (W.D. Pa. Sept. 2, 2025) (“Court finds that the omission of a one- or two-step

tasks limitation, and the lack of further explanation of the same, does not

undermine the ALJ's decision”).

The ALJ was under no obligation to either incorporate everything from the

state psychologists’ opinions nor exhaustively reject everything she chose not to

incorporate. Therefore, there is no legal error and the ALJ’s decision will be

affirmed.

c. The ALJ’s limitation to “Simple, Routine Tasks” does not

conflict with jobs with reasoning levels 2-3

Rooney’s third argument centers around the reasoning levels of the jobs

selected by the Vocational Expert. ECF No. 12 at 10-11. At Step 5, the Vocational

Expert selected jobs with DOT Reasoning Levels 2 or 3. ECF No. 3-2 at 23. See

also DOT definitions bottle packer (DOT code: 920.685-026, reasoning 2); marker

(DOT code: 209.587-034, reasoning 2); mail sorter (DOT code: 209.687-026,

reasoning 3). Rooney’s argues the ALJ did not resolve the “apparent and

unambiguous” conflict between an RFC limitation to “simple tasks,” and the

demands of jobs with level 2-3 reasoning levels – i.e. that the demands of these jobs

exceed “simple tasks.” ECF No. 12 at 10-11. The Commissioner responds there is

no conflict with the simple tasks limitation and the jobs that the ALJ found Rooney

could perform at Step Five. ECF No. 16 at 11 (citing Money v. Barnhart, 91 F.

App’x 210, 215 (3d Cir. 2004) (“[w]orking at reasoning level 2 [does] not contradict

the mandate that [a claimant’s] work be simple, routine, and repetitive.”)).

The Court agrees with the Commissioner. There is no conflict with the ALJ’s

limitation of “simple, routine tasks” and jobs with reasoning levels 2 or 3. There is

no bright-line rule stating when a per se conflict exists between an RFC limitation

and any certain reasoning level. Zirnsak v. Colvin, 777 F.3d 607, 618 (3d Cir. 2014).

DOT reasoning levels “refer to informal and formal levels of education

required for satisfactory job performance.” Veronica D. v. Comm'r of Soc. Sec., No.

1:24-CV-01326, 2025 WL 2665313, at *5 (M.D. Pa. Sept. 17, 2025) (internal citations

omitted). A job’s reasoning level “gauges the minimal ability a worker needs to

complete the job’s tasks themselves.” Id.

There is no conflict between simple, routine tasks and jobs with a reasoning

level of 2. In order to perform a job at reasoning level 2, an individual must be able

to “[a]pply commonsense understanding to carry out detailed but uninvolved

written or oral instructions [and] [d]eal with problems involving a few concrete

variables in or from standardized situations. Appendix C - Components of the

Definition Trailer, 1991 WL 688702. In Money v. Barnhart, 91 F. App'x 210, 215

(3d Cir. 2004), the Third Circuit Court of Appeals found that “[w]orking at

reasoning level 2 would not contradict the mandate that her work be simple, routine

and repetitive.” Id. Additionally, in a recent, similar case from the United States

District Court for the Middle District of Pennsylvania, after the plaintiff argued the

ALJ did not address the conflict between an RFC limiting plaintiff to “simple,

routine, and repetitive tasks” and jobs requiring a reasoning level of 2, the Court

found there was no inherent conflict between jobs with a reasoning levels of 2-3 and

simple, routine tasks. Veronica D., 2025 WL 2665313, at *5.

Other Courts in this Circuit have likewise recently found that reasoning level

2 jobs do not contradict a restriction to simple, routine tasks. See David D. v.

O'Malley, No. 3:22-CV-6413, 2024 WL 4635305, at *14 (D.N.J. Oct. 31, 2024) (“Nor

can the Court conclude that a mental limitation to ‘simple, routine tasks and ...

simple work-related decisions’ is inconsistent with the DOT definitions for routing

clerk and laundry worker, occupations that require reasoning level 2); Roecker v.

O'Malley, No. 3:24-CV-47, 2024 WL 3362284, at *10 (M.D. Pa. July 10, 2024) (“We

are also constrained to observe that courts have frequently sustained decisions like

the ALJ's determination in this case, which found that a claimant could perform

SVP level 2 jobs when the ALJ limited the claimant to simple tasks and restricted

the claimant's interaction with others.”); Buchinsky v. Kijakazi, No. CV 20-1906,

2022 WL 2987138, at *1 n. 1 (W.D. Pa. July 28, 2022) (“[R]easoning level of 2 does

not contradict a restriction to simple, routine, and repetitive tasks[.]”).

There is also no conflict between simple, routine tasks and jobs with a

reasoning level of 3. In order to perform tasks at a reasoning level of 3, an

individual must “[a]pply commonsense understanding to carry out instructions

furnished in written, oral, or diagrammatic form [and] [d]eal with problems

involving several concrete variables in or from standardized situations.” Appendix

C - Components of the Definition Trailer, 1991 WL 688702. The Third Circuit

Court of Appeals in Zirnsak v. Colvin found no “inherent conflict” between a job

requiring level 3 reasoning and a limitation to simple, routine tasks. 777 F.3d 607,

618 (3d Cir. 2014). Additionally, several District Courts within this Circuit have

found there is no per se conflict between jobs with level 3 reasoning and a limitation

to simple, routine tasks. See Veronica D., 2025 WL 2665313, at *6 (finding no

conflict between simple, routine tasks and jobs with reasoning level of 3);

Reichenbach v. Comm'r of Soc. Sec., No. CV 23-1100, 2024 WL 4336301, at *1 (W.D.

Pa. Sept. 26, 2024) (same).

Rooney notes the Commissioner only focused on jobs with a Reasoning Level

of 2 in his response brief, and Rooney argues the Commissioner has “seemingly

conced[ed] that the RFC would not be consistent with jobs at reasoning level 3.”

ECF No. 17 at 3. While the Commissioner did not address jobs with reasoning level

3 in his Opposition brief, that does not mean the ALJ made a legal error at Step 5

by finding Rooney could perform jobs with a Reasoning Level of 3.

The ALJ’s decision will therefore be affirmed.

VI. Conclusion

Accordingly, for the foregoing reasons, the final decision of the Commissioner

denying these claims will be AFFIRMED. Plaintiff’s Motion for Summary

Judgment is denied. An appropriate order follows.

DATED this 29th day of December, 2025.

BY THE COURT:

s/Christopher B. Brown

United States Magistrate Judge