Karla P. v. Bisignano

Background

Karla P. applied for supplemental security income (SSI) and disability insurance benefits (DIB) under the Social Security Act, claiming she was disabled. An administrative law judge (ALJ) conducted a hearing and evaluated her claim using the standard five-step sequential evaluation process set out in 20 C.F.R. § 404.1520(a)(4)(i)–(v).

At the hearing, Karla P. presented evidence of diagnoses including kidney disease, headaches, tachycardia, nevus pigmentosus, dermatoheliosis, elevated liver function tests, non-alcoholic steatohepatitis, anxiety, depression, and adjustment disorder. The ALJ found that Karla P. had several severe impairments — including degenerative disc disease of the cervical spine, hypertension, obesity, left distal clavicle osteolysis, major depressive disorder, generalized anxiety disorder, and adjustment disorder — but that none of these impairments met the criteria for automatic qualification for disability benefits under the applicable regulations.

The ALJ determined that Karla P. had a residual functional capacity (RFC) — meaning the most she could still do despite her limitations — to perform 'light work' subject to certain nonexertional limitations. One of those limitations was that she was restricted to 'brief and superficial interaction with supervisors/co-workers,' which the ALJ defined as meaning 'the 5th digit of the DOT code is a "7" or "8".'

The Dictionary of Occupational Titles (DOT) is a reference guide used by the Social Security Administration to classify jobs. The DOT assigns a 'people rating' — the fifth digit of each job's code — to describe the level of human interaction a job requires. A rating of '8' ('Taking Instructions-Helping') is the lowest level, involving attending to instructions from a supervisor with no immediate response required. A rating of '7' ('Serving') involves attending to the needs or requests of people with immediate response. Ratings of '0' through '6' involve progressively more complex forms of interaction, such as mentoring, negotiating, instructing, supervising, persuading, and speaking-signaling.

Based on these findings, the ALJ concluded Karla P. could perform jobs available in the national economy and denied her claim. Karla P. appealed to federal district court, where United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) on January 5, 2026, recommending that her appeal be denied.

Karla P.'s Objection

Karla P. timely objected to the R&R, raising one principal argument: that the ALJ erred by defining 'superficial' interaction as equivalent to a DOT people rating of '7' or '8' without adequate explanation, and that the equivalence was arbitrary and unsupported. Importantly, Karla P. did not dispute that multiple medical opinions in the record restricted her to superficial interaction with coworkers and supervisors. Her objection was solely to the ALJ's method of translating that limitation into DOT people-rating terms.

Karla P. also argued, citing Tiffany B. v. Kajakazi, No. 22-CV-1227 (D. Minn. 2023), that the DOT people-rating system does not represent a true hierarchy — the DOT itself cautions that the arrangement of its 'People' levels 'is somewhat arbitrary and can be considered a hierarchy only in the most general sense,' with 'considerable overlap among occupations.'

The Court's Analysis

Judge Bryan reviewed the record de novo (independently, without deference to the Magistrate Judge's conclusions) to determine whether the ALJ's decision was supported by substantial evidence. Substantial evidence, as defined by the Eighth Circuit, is 'less than a preponderance' but enough for a reasonable mind to find adequate support for the ALJ's conclusion. The court noted it cannot substitute its own judgment for the ALJ's or disturb the ALJ's credibility determinations and weighing of conflicting evidence. Even when the record could support contrary outcomes, a reviewing court will not reverse the ALJ as long as the decision falls within the available 'zone of choice.'

The court rejected Karla P.'s argument, finding that the ALJ did not err in equating 'superficial' interaction with a DOT people rating of '7' or '8.' The court cited Katie R. v. O'Malley, No. 23-CV-1139 (D. Minn. 2024), affirmed by the Eighth Circuit as Rygmyr v. Dudek, No. 24-2005 (8th Cir. Apr. 18, 2025), and noted that Karla P.'s argument had been 'consistently rejected by district courts, including courts in this District,' citing Julie P. v. O'Malley, No. 23-CV-2980 (D. Minn. 2024) (collecting cases).

On the hierarchy question, the court acknowledged the DOT's caution about overlap but credited the reasoning from Julie L.P. v. O'Malley, No. 23-cv-2980 (D. Minn. 2024), that 'a people relationship code of 8 represents the lowest possible level of human interaction that exists in the labor force.' The court characterized Karla P.'s argument as an attempt to create a 'manufactured inconsistency' between the medical opinions limiting her to superficial interaction and the RFC's expression of that limitation through DOT codes.

The court found the RFC, including the ALJ's definition of 'superficial' as equivalent to a people rating of '7' or '8,' was not in error and was supported by substantial evidence.

Disposition