Maricela R. v. Kijakazi

Background

Maricela R. applied for disability insurance benefits under Title II of the Social Security Act, alleging disability beginning April 17, 2015, based on physical and mental impairments. The application was denied initially and on reconsideration. After a hearing, an administrative law judge (ALJ) issued an unfavorable decision, and the Social Security Appeals Council declined review.

The ALJ found that Maricela R. had severe impairments involving degenerative disease of the spine and left shoulder. The ALJ determined that she retained the residual functional capacity (RFC)—the most she could still do despite her impairments—to perform light work, with specified limits on lifting, sitting, standing, walking, overhead reaching, and balancing. The ALJ concluded that she could perform her past relevant work as a Social Services Aide and therefore did not proceed to the next step, which asks whether she can perform other work in the national economy.

Issues and analysis

Maricela R. raised four arguments: that the ALJ incorrectly identified her past relevant work and failed to address her claimed inability to read English; that the ALJ incorrectly evaluated the severity of her impairments; that the ALJ improperly discounted her testimony; and that the ALJ improperly evaluated medical-opinion evidence.

The court reached the past-work issue. Maricela R. testified that her prior job involved duties such as transporting materials, setting up events, and carrying coffee equipment and other items weighing about 30 pounds; she also reported having lifted as much as 50 pounds. The vocational expert identified her past relevant work as a Social Services Aide, an occupation classified as light work, but testified that she could not perform the job as she actually performed it because those duties required medium exertion. The expert testified that she could perform the occupation as generally performed in the national economy.

The court found it unclear how the ALJ had classified Maricela R.’s prior work as a Social Services Aide. The court explained that the job may have been a composite job, meaning a job with significant elements of two or more occupations and no single matching entry in the Dictionary of Occupational Titles. When evaluating a composite job, the claimant must be able to perform all parts of the job as actually performed. The court concluded that the ALJ improperly relied on the job as generally performed even though the record indicated that Maricela R. had performed the work at the medium level while her RFC was limited to light work. The error was not harmless because it prevented proper consideration of whether she could perform other work at the next step.

Disposition

The court granted Maricela R.’s motion for summary judgment and denied the Commissioner’s cross-motion for summary judgment. It reversed the ALJ’s decision and remanded the matter for further administrative proceedings. The court declined to decide the other arguments, stating that the agency should consider them on remand. It also declined to order immediate payment of benefits because the record did not clearly require a finding that Maricela R. was disabled. Judge Thomas S. Hixson ordered that a separate judgment be entered and that the case be terminated afterward.