Karla P. v. Bisignano

Background

Karla P. applied for supplemental security income (SSI) — a federal benefit program for people with limited income and resources who are disabled — on the grounds that she was disabled as defined under the Social Security Act. An administrative law judge (ALJ) held a hearing at which Karla P. presented evidence of diagnoses including kidney disease, headaches, tachycardia, nevus pigmentosus, dermatoheliosis, elevated LFTs, non-alcoholic steatohepatitis, anxiety, depression, and adjustment disorder.

ALJ's Five-Step Analysis

Based on these findings, the ALJ concluded Karla P. was not entitled to SSI benefits. Karla P. sought judicial review.

Magistrate Judge's Report and Recommendation

United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) on January 5, 2026, recommending that Karla P.'s appeal be denied. Karla P. timely objected.

The Core Dispute: 'Superficial' and the DOT People Rating

Karla P.'s objection centered on the ALJ's translation of a 'superficial interaction' limitation into a specific DOT people rating. The DOT assigns jobs a fifth-digit code — the 'people rating' — describing the level of human interaction involved, ranging from '0' (Mentoring, the highest) to '8' (Taking Instructions-Helping, the lowest). A rating of '7' corresponds to 'Serving,' which involves attending to the needs or requests of people with immediate response involved. A rating of '8' corresponds to 'Taking Instructions-Helping,' involving attending to a supervisor's work assignment instructions where no immediate response is required unless clarification is needed.

Karla P. argued the ALJ never explained how 'superficial' equates to a people rating of 7 or 8 and that the equivalence was 'entirely arbitrary.' She also cited a prior district court decision, Tiffany B. v. Kajakazi, for the proposition that the DOT people ratings do not represent a true hierarchy, noting the DOT itself cautions that the arrangement 'is somewhat arbitrary and can be considered a hierarchy only in the most general sense.'

Court's Analysis

Judge Bryan conducted a de novo review (an independent, fresh examination) of the record under the substantial evidence standard — meaning enough evidence that a reasonable mind would find it adequate to support the ALJ's conclusion, though less than a preponderance. Under this standard, the court may not substitute its own judgment for the ALJ's or disturb the ALJ's credibility determinations and weighing of conflicting evidence.

The court rejected Karla P.'s argument on three grounds:

Consistent District Court Precedent The court noted that Karla P.'s argument — that an ALJ errs by equating 'superficial interaction' with a DOT people rating of 7 or 8 — has been 'consistently rejected' by district courts, including courts in the District of Minnesota. The court cited Katie R. v. O'Malley, which was affirmed by the Eighth Circuit Court of Appeals, and Julie P. v. O'Malley, among other cases.

No 'Manufactured Inconsistency' Karla P. did not dispute the multiple medical opinions in the record limiting her to superficial interaction with coworkers and supervisors. The court characterized her argument as an attempt to create a 'manufactured inconsistency' between those opinions and the RFC's ultimate limitations — an approach the court declined to accept.

DOT Rating of 8 Represents Lowest Interaction Level Even accepting that the DOT's hierarchy is not perfectly rigid, the court found that a people rating of 8 still represents the lowest possible level of human interaction recognized in the labor force. Courts have consistently concluded that an RFC limitation to 'brief and superficial' interaction is consistent with a DOT people rating of 7 or 8.

Disposition