Katie R. v. O'Malley

Background

Katie R. applied for supplemental security income on September 16, 2019. She alleged that she became disabled on January 23, 2019, because of chronic pain, lower-back and neck problems, post-traumatic stress disorder, depression, and anxiety. Her application was denied initially and again on reconsideration. After hearings, an Administrative Law Judge (ALJ) found that Katie R. had severe impairments involving her cervical and lumbar spine, chronic pain syndrome, major depressive disorder, generalized anxiety disorder, and post-traumatic stress disorder.

The ALJ determined that none of those impairments met or medically equaled a listed impairment. The ALJ found that Katie R. had the residual functional capacity (RFC)—her ability to work despite her impairments—for limited light work. The restrictions included no ladder, rope, or scaffold climbing; only occasional climbing of stairs and certain other physical activities; no work in high, exposed places; simple, routine, repetitive tasks; limited workplace changes; brief and superficial interactions with coworkers and supervisors; no complex decision-making; and no rapid, assembly-line-paced work.

After considering testimony from a vocational expert, the ALJ found that Katie R. could perform jobs existing in significant numbers in the national economy. The ALJ therefore found that she was not disabled. The Appeals Council denied review, and Katie R. sought judicial review.

Issue

Katie R. challenged the ALJ’s formulation of her RFC. She did not challenge the limitation to superficial contact itself. Instead, she argued that the ALJ improperly defined “brief and superficial” contact by limiting the relevant occupations to jobs whose Dictionary of Occupational Titles code had a fifth digit of 6, 7, or 8. She contended that this definition was not grounded in medical evidence and improperly took over the vocational expert’s role in determining which jobs were compatible with her limitations.

Court’s analysis

The Court explained that its review was limited to whether the Commissioner’s decision was supported by substantial evidence on the record as a whole. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

The Court held that the ALJ did not err by explaining the meaning of “superficial” contact with reference to the Dictionary of Occupational Titles. The ALJ appropriately identified Katie R.’s functional restrictions and described them to the vocational expert. The vocational expert testified that the Dictionary of Occupational Titles and its companion publication did not specifically address interactions with supervisors and coworkers, and that she relied on her education, training, and experience for that information. The Court concluded that the vocational expert took Katie R.’s restrictions into account when identifying jobs she could perform.

Disposition

The Court concluded that substantial evidence supported the ALJ’s finding that Katie R. was not disabled. It ordered that Katie R.’s motion for judgment be DENIED, the Commissioner’s motion for judgment be GRANTED, and the matter be DISMISSED with prejudice.