Automated Summary
Key Facts
Plaintiff Elizabeth G. appealed the denial of her Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI) applications. The ALJ denied her claim after finding she could perform light work and identify jobs like small products assembler I and production assembler. The court reversed this decision, concluding the ALJ failed to resolve an obvious conflict between Plaintiff's 'no assembly-line pace' limitation and the assembly-line job requirements described by the vocational expert. This error was not harmless as the only alternative job cited (sub-assembler) had insufficient job numbers to meet the 'significant' threshold.
Issues
The ALJ erred at step five by failing to reconcile the obvious conflict between Plaintiff's 'no assembly-line pace' limitation and the vocational expert's testimony identifying assembly line jobs (small products assembler I, production assembler) as suitable work. Courts require ALJs to address such conflicts before relying on vocational expert testimony.
Holdings
The court reversed the Commissioner's decision because the ALJ failed to reconcile the conflict between the plaintiff's 'no assembly-line pace' limitation and the assembly line job requirements identified by the vocational expert. The case is remanded for further proceedings to address this issue and determine if the plaintiff can perform other work in significant numbers.
Remedies
The court reverses the Commissioner's decision and remands for further proceedings consistent with this opinion.
Legal Principles
The court held that an ALJ must reconcile conflicts between a vocational expert's testimony and the Dictionary of Occupational Titles (DOT) when the conflict is obvious or apparent. This includes requiring the expert to explain how a claimant can perform jobs with assembly-line requirements despite limitations on assembly-line pace.
Precedent Name
- Shaibi v. Berryhill
- Rasmussen v. Kijakazi
- SSR 00-4P
- Valentine v. Comm'r Soc. Sec. Admin.
- Terry v. Sullivan
- Zavalin v. Colvin
- Smith v. Kijakazi
- Massachi v. Astrue
- Molina v. Astrue
- Brown-Hunter v. Colvin
- Lamear v. Berryhill
- Gutierrez v. Colvin
- Treichler v. Comm'r of Soc. Sec. Admin.
- Keyser v. Comm'r of Soc. Sec. Admin.
- De Rivera v. Berryhill
- Gutierrez v. Astrue
- Consolo v. Fed. Mar. Comm'n
Cited Statute
Social Security Act
Judge Name
Stacie F. Beckerman
Passage Text
- The ALJ concluded that Plaintiff was not disabled because a significant number of jobs existed in the national economy Plaintiff could perform, including small products assembler I, production assembler, and sub-assembler. (Tr. 32.)
- The Court finds that the ALJ erred by not resolving the conflict between the VE's testimony and the DOT. The Court reverses the Commissioner's decision and remands for further proceedings.
- If the expert's opinion that the applicant is able to work conflicts with, or seems to conflict with, the requirements listed in the [DOT], then the ALJ must ask the expert to reconcile the conflict before relying on the expert to decide if the claimant is disabled.