Courtney v. Commissioner, No. 17-1777 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the denial of plaintiff's claims for a period of disability, disability insurance benefits, and supplemental security income. The court held that Social Security Ruling (SSR) 00-4p makes clear that before relying on Vocation Expert (VE) evidence, adjudicators must identify and obtain a reasonable explanation for any conflicts between such evidence and the DOT. However, SSR 00-4p did not impose a duty on the ALJ to obtain a reasonable explanation when the VE simply testifies to information not found in the DOT—but that does not conflict with it. Therefore, the court agreed with the Commissioner that unless a VE's testimony appears to conflict with the DOT, there is no requirement that an ALJ inquire as to the precise basis for the expert's testimony regarding extra-DOT information. In this case, the ALJ described plaintiff's limitations to the VE, the VE responded with possible jobs, and the VE's testimony did not conflict with the DOT. Therefore, the ALJ was entitled to rely on the testimony and substantial evidence supported the agency's finding that plaintiff was not disabled.
Court Description: Smith, Author, with Melloy and Shepherd, Circuit Judges] Civil case - Social Security. The applicable regulations (SSR 00-4p) do not impose a duty on the ALJ to obtain a reasonable explanation when the Vocational Expert simply testifies to information which, while not in the Dictionary of Occupational Titles, does not conflict with the Dictionary; here, the ALJ described claimant's limitations to the Vocational Expert, who responded with possible jobs, and there was no conflict between the VE's testimony and the Dictionary; the ALJ was entitled, therefore, to rely on the testimony and conclude claimant was not disabled.
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