Facts

Plaintiff Daniel V. filed a complaint against defendant Kilolo Kijakazi, Commissioner of Social Security, seeking a review of Kijakazi's denial of his disability insurance benefits. At the hearing, the Administrative Law Judge (ALJ) found that Daniel suffered from the following impairments: post head trauma with post-traumatic stress disorder; depression; anxiety; obesity; and degenerative joint disease of the left wrist. At the hearing, the state agency psychological consultants maintained that Daniel only retained the ability for "simple and 2 step tasks."

PLAINTIFF'S CONTENTIONS: Plaintiff contended that the ALJ's residual functional capacity assessment failed to correctly reflect the opinions of two of the state agency psychological consultants.

DEFENDANT'S CONTENTIONS: Defendant contended that, given that the consultants stated opinions were more akin to the minimum Daniel could perform than the maximum, the ALJ was free to "reasonable interpret" the findings as supportive of "simple, routine tasks."

Result

The court agreed with plaintiff that an inconsistency existed and that although the ALJ purportedly found the state psychological consultants' opinions regarding Daniel's mental limitations to be entitled to great weight, the ALJ still failed to explain why she did not include the limitation to two-step instruction work in the residual functional capacity assessment and instead only limited Daniel to "simple, routine tasks." Because the Ninth Circuit has made clear that these two limitations are not equivalent, and the ALJ's residual functional capacity assessment did not account for that limitation, the case was reversed and remanded.