Summary
**Holding:** The Sixth Circuit affirmed denial of Social Security disability benefits, holding that a vocational expert's testimony that 32,000 national jobs existed for a claimant with peripheral neuropathy constituted substantial evidence, even without the expert producing underlying survey data. The court rejected the argument that an ALJ has a "heightened duty" to develop the record for a pro se claimant under *Lashley v. Secretary of Health & Human Services*; that special duty applies only in extreme circumstances (e.g., illiteracy, confusion) not present here. The concurrence criticized *Lashley* as an atextual, unworkable standard inconsistent with modern administrative law.
Topics
Practice areas
Questions Presented
- Whether the vocational expert's testimony constituted substantial evidence supporting the ALJ's decision.
- Whether the ALJ had a heightened duty to develop the record because Moats was unrepresented.
Holdings
- The vocational expert's testimony that Moats could perform a significant number of jobs in the national economy was substantial evidence supporting the ALJ's decision.
- The ALJ did not have a heightened duty beyond the general duty to ensure a full and fair hearing, and the record was adequately developed.
Key quotations
“'[S]ubstantial evidence' is a 'term of art' in this setting. And it is 'not [a] high' threshold. While it requires 'more than a mere scintilla' of evidence, substantial evidence 'means only . . . such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'” (Page 4)
“the expert's uncontradicted testimony easily qualifies as 'the kind of evidence—far more than a mere scintilla—that a reasonable mind might accept as adequate to support a finding about job availability.'” (Page 6)
“Lashley is best viewed as an extreme example of an ALJ failing to adequately develop the record before it.” (Page 7)
“Thankfully, Moats's case is not one of extreme circumstances.” (Page 8)
Factual background
Todd Moats suffers from peripheral neuropathy, which prevents him from wearing closed-toed shoes for long periods. He left his job as a forklift operator and applied for disability benefits. At the hearing, Moats appeared without counsel. The ALJ heard testimony from Moats, his wife, and a vocational expert. The vocational expert testified that Moats could perform about 32,000 jobs in the national economy, such as general office clerk, addresser, and surveillance monitor. The ALJ denied benefits, finding that Moats could perform a significant number of jobs. The district court affirmed.
Procedural history
Moats applied for disability benefits; the ALJ denied benefits; the district court affirmed; Moats appealed to the Sixth Circuit.