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Analysis
Leo AI

Step Three

The brief argues medical equivalence to Listing 1.17 rather than a strict “meets” theory because the assistive-device documentation does not cleanly satisfy paragraph C's requirements under SSA's formal documentation rule. That is the weakest element. The surgery history and 12-month duration are strong.

The brief counters the paragraph C weakness by stacking evidence: the March 2023 parking certification for inability to walk 200 feet, repeated observations of cane-assisted ambulation, a formal wheeled walker fitting, sitting-only work restrictions, a documented fall from knee buckling, and post-revision therapy deficits. Individually, no single piece is airtight. Together, they make a credible equivalence case.

I chose 1.17 over 1.18 because the serial reconstructive surgery history made the theory cleaner and more intuitive for the ALJ.

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Every argument in your brief comes with the strategy behind it. What was chosen, what was dropped, and where it's vulnerable.

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Leo has read every page of your client's file.
Ask things like:

  • “Why did you choose Listing 1.15 over 1.18?”
  • “What impairments did you consider but decide against, and why?”
  • “What are the weakest points in this case?”
  • “Summarize Dr. Rivera's treatment notes”
  • “If the ALJ finds the claimant can do light work, do the Grid Rules still direct disabled?”
Analysis
Leo AI
I'm Leo. I wrote this brief — ask me anything about it.
What evidence supports limiting the claimant to sedentary work?
The strongest piece is the treating orthopedist's restriction to “sitting down type work only” with no commercial driving or heavy equipment at Exhibit 12F p. 200. That's supported by the walking certification at Exhibit 12F p. 210 documenting inability to walk 200 feet, persistent cane ambulation on exam at Exhibit 20F pp. 1-2, and physical therapy findings showing right knee extension at 2-/5 and flexion at 2+/5 with antalgic gait at Exhibit 24F pp. 6-9.
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Click any citation.
See the source.

Click any citation in your brief to see the exhibit, the page, and the relevant excerpt from the record.

“...broad-based disc herniation at L4-L5 with moderate bilateral foraminal stenosis and compression of the traversing L5 nerve roots” Exhibit 11F p. 4

Exhibit 11F p. 4

MRI Lumbar Spine Without Contrast

Technique: Sagittal T1, T2, STIR. Axial T2 at L3-L4 through L5-S1.

L3-L4: Mild disc desiccation. No significant canal stenosis or neural foraminal narrowing.

L4-L5: Broad-based disc herniation with moderate bilateral foraminal stenosis. There is effacement of the ventral thecal sac and compression of the traversing L5 nerve roots bilaterally.

L5-S1: Mild disc bulge. Mild facet arthropathy. No significant stenosis.

Impression: Broad-based disc herniation at L4-L5 with moderate bilateral foraminal stenosis and L5 nerve root compression. Mild degenerative changes at remaining levels.

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