Joseph T. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviewed the Commissioner of Social Security’s denial of Joseph T.’s application for Supplemental Security Income. The court found that the ALJ failed to resolve an apparent conflict between the vocational expert’s testimony and the Dictionary of Occupational Titles regarding reaching requirements, vacated the Commissioner’s decision, and remanded for further administrative proceedings.

Holdings

1. The ALJ's finding that Joseph could perform work as a marker, collator operator, or router despite limiting him to occasional overhead reaching created an apparent conflict with the Dictionary of Occupational Titles, which describes those occupations as requiring frequent reaching.
2. The vocational expert's statement that her opinion was based on her knowledge, training, and experience did not provide the reasonable explanation required to reconcile the conflict between the DOT and her testimony.
3. The ALJ's step-five determination was not supported by substantial evidence because the ALJ failed to identify, explain, and resolve the apparent conflict between the vocational expert's testimony and the DOT.

Questions Presented

1. Whether the ALJ failed to resolve an apparent conflict between the vocational expert's testimony that Joseph could perform identified jobs with only occasional overhead reaching and the Dictionary of Occupational Titles' description of those jobs as requiring frequent reaching.
2. Whether the unresolved conflict rendered the ALJ's step-five determination unsupported by substantial evidence and required remand.

Disposition

reversed_and_remanded