S.C. v. Saul

Background

S.C. applied for disability benefits, alleging disability beginning October 22, 2013. After his application was denied initially and on reconsideration, he received a hearing before an administrative law judge (ALJ) on June 28, 2018. The ALJ found that S.C. was not disabled, and the Appeals Council declined to review that decision.

At the hearing, a vocational expert testified that a person with S.C.'s impairments could perform work as a Counter Clerk, Laminating Machine Operator, and Mill Stenciler. The expert gave job numbers for those positions and said the information came from the Dictionary of Occupational Titles and Job Browser Pro software. After the hearing, S.C.'s attorney objected that the numbers appeared to describe broad job categories rather than the specific occupations identified by the expert. The attorney later obtained information showing substantially different numbers for the specific positions. The ALJ did not address those objections in the written decision.

Parties' Positions

S.C. argued that the case should be remanded for immediate payment of benefits. He contended that another hearing would waste agency and judicial resources and expressed concern that further proceedings could cause additional delay or allow the Commissioner to repeat inaccurate testimony.

The Commissioner agreed that the job numbers identified by the ALJ and vocational expert were unsupported but requested a remand for further proceedings instead of immediate payment. The court found no evidence that the inaccurate testimony was provided in bad faith and said it appeared possible that the expert had accidentally used numbers for job categories rather than specific occupations.

Court's Analysis

The court found that the ALJ made two errors: relying on inaccurate vocational-expert data and failing to address S.C.'s properly filed post-hearing objection to that data. Because the record was not fully developed and ambiguities remained, further proceedings were useful and necessary.

The court declined to receive the new evidence itself. It explained that a reviewing district court examines ALJ decisions rather than conducting its own hearings on the merits of a disability application.

Disposition

The case was remanded for further proceedings. The ALJ must hear new testimony from a vocational expert, obtain accurate information about the number of relevant jobs in the national economy, and use that information to reach a new conclusion about whether S.C. is disabled. The court did not order immediate payment of benefits.

The court also ordered that, if S.C. seeks review of the next ALJ hearing, the Commissioner must provide a copy of this order to the reviewing district court judge so there will be a record of any pattern of false testimony.