Joseph M. G. v. Saul

Background

Joseph M. G. sought judicial review of an administrative decision that partially denied his application for disability insurance benefits. Magistrate Judge Hildy Bowbeer recommended granting the Commissioner of Social Security’s motion for summary judgment and denying Joseph’s motion for summary judgment. Joseph filed objections, requiring the district court to review the recommendation independently.

Court’s analysis

The dispute concerned the administrative law judge’s finding that, before September 26, 2017, Joseph retained the residual functional capacity to perform his past relevant work as a machinist. A vocational expert testified that a person with Joseph’s functional limitations, including the ability to sit, stand, or walk for approximately six hours during an eight-hour workday, could not perform the machinist job because it required standing and walking for more than six hours. The vocational expert also testified that most medium-level jobs required being on one’s feet for eight hours.

The administrative law judge rejected that testimony after explaining that it conflicted with the Social Security Administration’s Program Operations Manual, which states that medium work usually requires walking or standing for approximately six hours per day. The court found that this guidance was consistent with the applicable regulations and other authorities. Joseph did not otherwise challenge the six-hour limitation in the administrative law judge’s residual-functional-capacity assessment. The court therefore found substantial evidence supporting the conclusion that Joseph could perform his past relevant work before September 26, 2017.

Disposition

Judge Eric C. Tostrud overruled Joseph’s objections and accepted the Report and Recommendation in full. The court denied Joseph’s motion for summary judgment, granted the Commissioner’s motion for summary judgment, and dismissed the action with prejudice. The court directed that judgment be entered accordingly.