Everick James W. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviewed the denial of Everick James W.'s application for Supplemental Security Income benefits. The court held that the Administrative Law Judge adequately addressed the alleged conflict between vocational-expert testimony and the Dictionary of Occupational Titles, did not rely on Emergency Message 21065, and sufficiently translated the claimant's mental limitations into the residual functional capacity assessment. The court affirmed the Commissioner's decision.

Holdings

1. The ALJ did not commit reversible error in relying on the vocational expert's testimony. The Third Circuit does not recognize a categorical conflict between a limitation to simple work and occupations requiring reasoning level 3; any possible conflict concerning the reasoning level 4 occupation was harmless because other identified occupations provided more than 57,000 jobs in the national economy.
2. The court declined to address Plaintiff's challenge to Emergency Message 21065 because the ALJ did not rely on it and the Social Security Administration did not rely on it in defending the decision.
3. An ALJ's finding of moderate Paragraph B limitations at steps two and three does not automatically require identical language or additional restrictions in the RFC. The RFC is sufficient when the ALJ adequately explains how the evidence supports the functional limitations adopted.

Questions Presented

1. Whether the vocational expert's testimony conflicted with the Dictionary of Occupational Titles because the ALJ limited Plaintiff to simple instructions while identifying occupations with reasoning levels 3 and 4.
2. Whether the Social Security Administration improperly relied on Emergency Message 21065 to prohibit consideration of reasoning levels.
3. Whether the ALJ's residual functional capacity assessment was legally inconsistent with findings of a severe mental impairment and moderate Paragraph B limitations.

Disposition

affirmed