Menkes v. Comm Soc. Sec., 262 F. App'x 410 (3rd Cir. 2008). · Go Syfert
Menkes v. Comm Soc. Sec., 262 F. App'x 410 (3rd Cir. 2008). Cases Citing This Book View Copy Cite
“having previously acknowledged that suffered moderate limitations in concentration, persistence and pace, the alj accounted for these mental limitations in the hypothetical question by restricting the type of work to 'simple routine tasks.”
53 citation events (53 in the last 25 years) across 7 distinct courts.
Strongest positive: WILSON v. COMMISSIONER OF SOCIAL SECURITY (njd, 2025-07-23)
Treatment trajectory · 2012 → 2026 · click a year to view as-of
2012 2019 2026
Top citers, strongest first. 23 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) WILSON v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2025 · signal: see also · quote attribution · 1 verbatim quote · confidence high
performing a 'simple routine task' typically involves low stress level work
discussed Cited as authority (verbatim quote) Slagle v. Saul
W.D. Va. · 2022 · quote attribution · 1 verbatim quote · confidence high
erforming a 'simple routine task' typically involves low stress level work that does not require maintaining sustained concentration.
examined Cited as authority (verbatim quote) Armstrong v. Berryhill
S.D. Tex. · 2020 · quote attribution · 1 verbatim quote · confidence high
having previously acknowledged that suffered moderate limitations in concentration, persistence and pace, the alj accounted for these mental limitations in the hypothetical question by restricting the type of work to 'simple routine tasks.
discussed Cited as authority (rule) COYNE v. COMMISSIONER OF SOCIAL SECURITY
W.D. Pa. · 2024 · confidence medium
Appx. 941, 946-47 (3d Cir. 2008) (stating the ALJ’s RFC limiting claimant to simple, routine tasks adequately accounted for claimant’s moderate limitations in concentration, persistence and pace); Menkes v. Astrue, 262 Fed.
discussed Cited as authority (rule) CHARLTON v. KIJAKAZI
E.D. Pa. · 2023 · confidence medium
App’x 941, 946 85 n.10 (3d Cir. 2008) (limitation to “simple, routine tasks” was sufficient to account for moderate restrictions in concentration, persistence, or pace because, unlike in Ramirez, claimant did not “often” suffer from these deficiencies); Menkes v. Astrue, 262 F. App’x 410, 412 (3d Cir. 2008) (same); see also Jefferson v. Colvin., No 16-cv-2665, 2017 WL 2199064 , at *1 (E.D.
discussed Cited as authority (rule) MAZUREK v. KIJAKAZI, ACTING COMMISSIONER OF SOC. SEC.
E.D. Pa. · 2023 · confidence medium
Moreover, the Third Circuit has held that the term “simple routine tasks” generally refers to the non-exertional or mental aspects of work and typically involves low stress level work that does not require maintaining sustained concentration, Menkes v. Astrue, 262 F. App’x 410, 412 (3d Cir. 2008), and courts in this jurisdiction have found that an ALJ’s hypothetical question limiting a plaintiff to simple, repetitive tasks sufficiently covers the need to work in a low stress environment.
discussed Cited as authority (rule) BURRELL v. COMMISSIONER OF SOCIAL SECURITY
E.D. Pa. · 2022 · confidence medium
See, e.g., McDonald v. Astrue, 293 Fed.Appx. 941 , 946 85 n.10 (3d Cir. 2008) (limitation to “simple, routine tasks” was sufficient to account for moderate restrictions in concentration, persistence, and pace because unlike in Ramirez, the claimant did not “often” suffer from these deficiencies) (not precedential); Menkes v. Astrue, 262 Fed.Appx. 410, 412 (3d Cir. 2008) (same); see also Jefferson v. Colvin, 2017 WL 2199064 , at *1 (E.D.
discussed Cited as authority (rule) HARVEY v. COMMISSIONER OF SOCIAL SECURITY
W.D. Pa. · 2021 · confidence medium
Sec., 931 F.3d 198, 210 (3d Cir. 2019)(simple tasks can fairly reflect “moderate difficulties in ‘concentration, persistence, or pace’…if an ALJ provides a ‘valid explanation’”); McDonald v. Astrue, 293 F. App’x 941, 946-47 (3d Cir. 2008); Menkes v. Astrue, 262 F. App'x 410, 412 (3d Cir. 2008) (“The term ‘simple routine tasks,’ in the context of the disability proceedings, generally refers to the non-exertional or mental aspects of work.
discussed Cited as authority (rule) WASHINGTON v. COMMISSIONER OF SOCIAL SECURITY
E.D. Pa. · 2020 · confidence medium
As the ALJ explained, Dr. Wells concluded that Washington had the following limitations: mild limitations [in] understanding, remembering, and carrying [out] simple instructions, and mak[ing] judgments on simple work-related decisions; interacting appropriately with the public, supervisors, and co-workers; and responding appropriately to usual work situations and to changes in a routine work setting. . . . [As well as] moderate difficulty [in] understanding, remembering, and carrying out complex instructions, and mak[ing] judgments on complex work-related decisions. 5 The performance of a simp…
discussed Cited as authority (rule) Wilson v. Berryhill
M.D. Penn. · 2020 · confidence medium
P. 72(b), and following de novo review of the contested portions of the report, see E.E.O.C. v. City of Long Branch, 866 F.3d 93, 99 (3d Cir. 2017) (quoting 28 U.S.C. § 636 (b)(1)), and affording “reasoned consideration” to the uncontested portions, see id. (quoting Henderson v. Carlson, 812 F.2d 874, 878 (3d Cir. 1987)),1 the court agreeing with Judge Arbuckle that the ALJ’s decision “is supported by substantial evidence,” 42 U.S.C. § 405 (g), a standard of review that the Supreme Court of the United States recently reiterated “is not high,” Biestek v. Berryhill, 587 U.S. ___ …
cited Cited as authority (rule) RAMOS v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2019 · confidence medium
Sec., 401 F. App’x 651, 655-56 (3d Cir. 2010); Menkes v. Astrue, 262 Fed.Appx. 410, 412-13 (3d Cir. 2008); McDonald v. Astrue, 293 F. App’x 941, 946-47 (3d Cir. 2008).
discussed Cited as authority (rule) WESTBROOK v. BERRYHILL
E.D. Pa. · 2019 · confidence medium
Pa. Nov. 18, 2013) at *17 citing McDonald v. Astrue, 293 F. App’x 941, 946-7 (3d Cir. 2008), and Menkes v. Astrue, 262 F. App’x 410, 412-3 (3d Cir. 2008), and see Parks v. Commissioner of Social Security, 401 F. App’x 651, 655-6 (3d Cir. 2010); Gunter v. Colvin, 2014 WL 4186501 at *4 (E.D.
discussed Cited as authority (rule) NASH v. BERRYHILL
W.D. Pa. · 2019 · confidence medium
See, e.g., McDonald v. Astrue, 293 F. App’x 941 , 946- 47 (3d Cir. 2008); Menkes v. Astrue, 262 F. App'x 410, 412 (3d Cir. 2008) (“The term ‘simple routine tasks,’ in the context of the disability proceedings, generally refers to the non-exertional or mental aspects of work.
discussed Cited as authority (rule) Gonzales v. Colvin
M.D. Penn. · 2015 · confidence medium
As the undersigned explained in Gray: Other courts have relied on nonprece-dential opinions, McDonald v. Astrue, 293 Fed.Appx. 941 , 946 & n. 10 (3d Cir. 2008) and Menkes v. Astrue, 262 Fed.Appx. 410, 412 (3d Cir. 2008), to conclude that Ramirez does not apply to cases after 2000 that use the severity scale instead of the frequency scale.
cited Cited as authority (rule) Holley v. Colvin
D.N.J. · 2013 · confidence medium
See McDonald v. Astrue, 293 Fed.Appx. 941, 946 (3d Cir.2008); Menkes v. Astrue, 262 Fed.Appx. 410, 412 (3d Cir.2008).
cited Cited as authority (rule) Sweeney v. Commissioner of Social Security
W.D. Pa. · 2012 · signal: cf. · confidence medium
Cf. Menkes v. Astrue, 262 Fed.
discussed Cited "see" HOOGERHYDE v. O'MALLEY
E.D. Pa. · 2024 · signal: see · confidence high
R. 16-17, 24; see Menkes v. Astrue, 262 F. App’x 410, 412 (3d Cir. 2008) (noting simple, routine tasks in disability proceedings “refer to non-exertional or mental aspects of work” and “performing a ‘simple routine task’ typically involves low stress and does not require maintaining concentration.”).
examined Cited "see" GORDEN v. COMMISSIONER OF SOCIAL SECURITY (4×)
D.N.J. · 2024 · signal: see · confidence high
See id.
cited Cited "see" LINDEMEYER v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2020 · signal: see · confidence high
See Menkes v. Astrue, 262 Fed.
discussed Cited "see" STEUTH v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2020 · signal: see · confidence high
See Menkes v. Astrue, 262 F. App’x 410, 412 (noting that including a limitation of “simple routine tasks” in a hypothetical question to a VE took into account a claimant’s moderate limitations in concentration, persistence, and pace.”).
cited Cited "see" Sawyer v. Berryhill
E.D. Pa. · 2018 · signal: see · confidence high
See Menkes , 262 Fed.Appx. at 412 .
discussed Cited "see, e.g." VREELAND v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2024 · signal: compare · confidence low
Compare Burns, 312 F.3d at 122 (finding that one question merely referring to “simple repetitive one, two- step tasks” failed to incorporate plaintiff’s borderline intellectual functioning and was thus deficient), with Menkes v. Astrue, 262 F. App’x 410, 412-13 . (3d Cir. 2008) (finding “no error in the hypothetical question or in the ALJ’s conclusion” because “[h]aving previously acknowledged "The ALJ further added to the hypothetical and asked if the same individual would be able to maintain work if the individual: (1) “would end up being off task an[d] unproductive 15 to 2…
discussed Cited "see, e.g." CODIROLI v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2022 · signal: see also · confidence low
Plaintiff’s Memorandum of Law, ECF No. 19, p. 24; see also Menkes v. Astrue, 262 F. App’x 410 , 412–13 (3d Cir. 2008) (“The term ‘simple routine tasks,’ in the context of the disability proceedings, generally refers to the non-exertional or mental aspects of work.
Retrieving the full opinion text from the archive…
Mina MENKES, Appellant
v.
Michael J. ASTRUE, Commissioner Social Security
07-2457.
Court of Appeals for the Third Circuit.
Jan 30, 2008.
262 F. App'x 410
Mina Menkes, Philadelphia, PA, pro se., David F. Chermol, Taryn Jasner, Social Security Administration, OGC/Region III, Philadelphia, PA, for Michael J. Astrue, Commissioner Social Security.
McKee, Smith, Chagares.
Cited by 38 opinions  |  Unpublished

OPINION

PER CURIAM.

Mina Menkes appeals pro se from an order of the United States District Court for the Eastern District of Pennsylvania denying her motion for summary judgment and granting the Commissioner of Social Security’s motion for summary judgment in this disability insurance benefits action. We will affirm.

I.

Because the facts are familiar to the parties and are thoroughly set forth in the Administrative Law Judge’s (“ALJ”) Decision and the Magistrate Judge’s Report, we will provide only a brief summary of the events leading up to this appeal. In January 2003, Menkes protectively filed for Social Security disability insurance benefits under the Social Security Act, claiming that she was disabled due primarily to head injuries sustained in an automobile accident on September 24, 2001. The Social Security Administration denied her application on June 23, 2003. At Menkes’s request, an ALJ held a hearing on the denial, at which Menkes and a vocational expert testified. The ALJ also reviewed objective medical evidence and the opinions of several physicians. Based on this evidence, the ALJ determined that Menkes “suffered from traumatic brain dysfunction with headaches, which are considered severe impairments.” The ALJ concluded, though, that while Menkes was unable to continue her past relevant work as a clerical worker, child care worker, or school bus driver, and while she had moderate restrictions in “concentration, persistence, and pace,” she retained the residual functional capacity to perform simple routine jobs that exist in significant numbers in the national and regional economy. Consequently, by decision dated July 9, 2004, the ALJ denied Menkes’s claim for benefits. The Appeals Council denied Menkes’s request for review, rendering the ALJ’s decision the final decision of the Commissioner. See 20 C.F.R. § 416.1481.

Menkes, represented by counsel, filed a civil action in the United States District Court for the Eastern District of Pennsylvania, seeking judicial review of the Commissioner’s final decision. Both parties moved for summary judgment. The District Court adopted the Magistrate Judge’s Report and Recommendation, denied Menkes’s motion, and granted the Commissioner’s motion. Menkes appealed pro se.

II.

We have appellate jurisdiction under 42 U.S.C. § 405(g) and 28 U.S.C. § 1291. Our role is identical to that of the District Court. We will uphold the ALJ’s findings if they are supported by substantial evidence. See 42 U.S.C. § 405(g); Burns v. Barnhart, 312 F.3d 113, 118 (3d Cir.2002). Substantial evidence “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Hartranft v. Apfel, 181 F.3d 358, 360 (3d Cir.1999), citing Pierce v. Underwood, 487 U.S. 552, 108 S.Ct. 2541, 101 L.Ed.2d 490 (1988).

Menkes’s primary contentions on appeal are that the ALJ and the Magistrate Judge exaggerated the importance of certain facts and that the ALJ erroneously[*412] ruled that she retained the physical and mental capacity to perform simple, routine work. After thoroughly reviewing the administrative record (including Menkes’s medical records), we agree with the Magistrate Judge’s reasoning and conclusion that substantial evidence supports the ALJ’s ruling that Menkes can perform certain simple routine work despite her physical impairment. The ALJ correctly considered all of the medical evidence, Menkes’s subjective testimony, and the testimony of the vocational expert, in determining that she was not disabled during the period between September 24, 2001 and June 30, 2003, and thus, she was not entitled to benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401-433.

III.

Menkes claims that, in determining her residual functional capacity, the ALJ attributed far too much weight to the fact that Menkes continued to take computer courses after her injuries and received A’s and B’s. She says that she had to minimize her course-load after the accident by switching from credit to “audit” status in some of the computer courses. Menkes explains that she received A’s and B’s because she either had read the book before or had a working knowledge of the course content prior to the accident. The ALJ’s decision shows that he based his determination of Menkes’s residual functional capacity on all of the evidence, not just her ability to attend, and perform well in, a few computer classes. He found that her treating and evaluating physicians consistently referred to her impairment as mild or moderate, that the objective testing was unremarkable, and that her neuropsychological exam was normal. Menkes testified that she could perform her own activities of daily living (including cooking), although it was a struggle to do so, and that she could also shop at least once a week. The ALJ also noted that the record indicated that Menkes had been able to take care of her mother when her mother fell ill for a short period after Menkes’s accident. Thus, contrary to Menkes’s belief that the ALJ denied her disability benefits because “a person taking two hours of class twice a week” constitutes “substantial gainful activity,” his decision draws no such conclusion, nor does it lend too much significance to Menkes’s computer course-work.

Menkes also complains that the ALJ erred in deciding that she was not disabled based on the vocational expert’s answer to the ALJ’s question regarding her ability to perform simple routine tasks. The term “simple routine tasks,” in the context of the disability proceedings, generally refers to the non-exertional or mental aspects of work. For example, performing a “simple routine task” typically involves low stress level work that does not require maintaining sustained concentration. The ALJ asked the vocational expert a hypothetical question that took into account Menkes’s vocational background in skilled and semi-skilled work and the lack of any physical exertional impairment. Having previously acknowledged that Menkes suffered moderate limitations in concentration, persistence and pace, the ALJ also accounted for these mental limitations in the hypothetical question by restricting the type of work to “simple routine tasks.” He asked the vocational expert, “Would the limitation to simple routine tasks preclude this hypothetical individual from performing the skilled and semi-skilled work that Ms. Menkes has done in the past,” to which the vocational expert relied, “Yes.” The ALJ then focused on how the limitation to simple routine tasks would preclude a person like Menkes from finding unskilled jobs available in the national and regional economy by asking “Would a limitation to simple routine tasks have any effect on the unskilled occupational base?” The voca[*413] tional expert replied, “No.” We find no error in the hypothetical question or in the ALJ’s conclusion, using Medical-Vocational Guidelines as a framework, that simple, routine, unskilled jobs existed that Menkes could perform.

IV.

We have considered all of Menkes’s arguments on appeal and conclude that they are unavailing. For the reasons stated, we will affirm the order of the District Court.