Chad H. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland remands the Commissioner of Social Security’s denial of Chad H.’s Supplemental Security Income claim. The court holds that the ALJ’s residual functional capacity limitation barring work with “specific production rates” was undefined and ambiguous, preventing meaningful judicial review and undermining the step-five vocational-expert finding. The remand is ordered under sentence four of 42 U.S.C. § 405(g).

Holdings

1. An RFC limitation using the undefined and ambiguous phrase "specific production rates," without an explanation of the metric, standard, or expectation involved, is insufficiently clear to permit meaningful judicial review.
2. Restrictions concerning simple job instructions and limited interaction with supervisors, coworkers, and the public do not, standing alone, clarify an ambiguous production-rate restriction.
3. Plaintiff did not forfeit the challenge merely by failing to seek clarification of the vocational-expert hypothetical at the administrative hearing where the same ambiguous term appeared in both the RFC assessment and the hypothetical.

Questions Presented

1. Whether the ALJ's residual-functional-capacity limitation restricting Plaintiff to work without "specific production rates" was sufficiently defined to permit meaningful judicial review.
2. Whether the ALJ's use of the undefined phrase "specific production rates" required remand because the phrase undermined the vocational-expert hypothetical and the step-five finding.
3. Whether Plaintiff forfeited the challenge by failing to seek clarification of the vocational-expert hypothetical at the administrative hearing.

Disposition

reversed_and_remanded