Maryan H. S. v. Saul

Background

Maryan H. S. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her applications for disability insurance benefits and supplemental security income. She alleged disability beginning October 22, 2013, based on leg and foot ailments. An administrative law judge (ALJ) held a hearing and found that she was not disabled.

The ALJ determined that Maryan H. S. had the residual functional capacity (RFC)—the most she could still do despite her limitations—to perform light work with additional restrictions. Those restrictions included lifting and carrying 20 pounds occasionally and 10 pounds frequently, sitting for six hours, and standing or walking for two hours during an eight-hour workday. The ALJ found that she could not perform her past relevant work but could perform other jobs identified by a vocational expert.

Issue and Analysis

Maryan H. S. argued that the ALJ failed to explain how her exertional capacity fit within the Social Security definitions of light and sedentary work. She specifically argued that her two-hour standing and walking limitation, together with the light-work requirement of frequent lifting and carrying, placed her between those two categories. She also argued that the ALJ failed to make the finding required by the agency’s Program Operations Manual System about whether her capacity was slightly or significantly reduced from the higher exertional level.

The court agreed that the ALJ had not adequately explained the RFC classification. Light work requires a good deal of walking or standing, or sitting most of the time with some pushing and pulling of arm or leg controls. The court concluded that the jobs identified by the vocational expert did not require a good deal of walking or standing or the relevant pushing and pulling, and that the jobs, when adjusted for Maryan H. S.’s limitations, were more properly classified as sedentary work.

The court also found that the ALJ did not resolve the practical inconsistency between the two-hour standing and walking limitation and the frequent lifting and carrying associated with light work. The ALJ did not determine whether Maryan H. S.’s exertional capacity was slightly or significantly reduced from light work, as required by the cited agency guidance and Social Security Ruling 83-12. Because the court ordered a remand on this issue, it declined to decide the argument about the extent of erosion of the occupational base.

Disposition

Judge Becky R. Thorson granted Maryan H. S.’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, and remanded the matter to the Commissioner for further proceedings under sentence four of 42 U.S.C. § 405(g). The ALJ was directed to reconsider the claimant’s exertional capacity, explain how her activity limitations relate to the definitions of light and sedentary work, and ensure that any identified jobs accurately reflect those limitations.