Evangelina T. v. Commissioner Social Security Administration

Summary

The United States District Court for the District of Oregon reviewed the denial of Evangelina T.'s application for disability insurance benefits. The court held that the ALJ failed to resolve an apparent conflict between the claimant's residual functional capacity and the reasoning requirements of two identified occupations under the Dictionary of Occupational Titles. The court reversed the Commissioner's decision and remanded for further administrative proceedings.

Holdings

1. When there is an apparent conflict between a claimant's residual functional capacity and the vocational expert's testimony concerning the requirements of identified occupations, the ALJ must ask the vocational expert to explain the conflict and determine whether the explanation is reasonable before relying on the testimony. Because the ALJ did not do so here, the court could not determine whether the step-five finding was supported by substantial evidence.
2. Remand for further administrative proceedings, rather than an immediate award of benefits, was appropriate because the court could not determine with certainty whether work existed in significant numbers in the national economy that Plaintiff could perform.

Questions Presented

1. Whether the ALJ's step-five finding was supported by substantial evidence when the ALJ did not address an apparent conflict between Plaintiff's residual functional capacity limiting her to short, simple, routine, and repetitive tasks and the level-three reasoning requirements of two identified occupations.
2. Whether the appropriate remedy was remand for further administrative proceedings or an immediate award of benefits.

Disposition

reversed_and_remanded