Zavalin v. Colvin

Plaintiff appealed the district court's affirmance of the Commissioner's denial of Supplemental Security Income (SSI) disability benefits, arguing that the ALJ failed to reconcile an apparent conflict between his residual functional capacity (RFC) and the reasoning requirements of the jobs identified by the ALJ. The ALJ found that plaintiff retains the RFC to perform simple, routine, or repetitive tasks and that plaintiff was not disabled because he is still able to perform two occupations: cashier and surveillance system monitor. These occupations require the ability to perform Level 3 Reasoning on the Department of Labor's General Education Development scale. The court agreed with plaintiff's argument and held that there is an apparent conflict between plaintiff's limitation to simple, routine, or repetitive tasks and the demands of Level 3 Reasoning. The court reversed and remanded for further proceedings because the ALJ failed to reconcile this apparent conflict. View "Zavalin v. Colvin" on Justia Law