Macfarlane v. Social Security Administration, Commissioner

Linda Macfarlane applied for Social Security Disability Insurance and Supplemental Security Income, claiming several physical and mental impairments. An administrative law judge (ALJ) denied the claims, determining that she could perform her past relevant work as a cashier. The district court affirmed the denial. On appeal, the United States Court of Appeals for the Ninth Circuit, in a decision dated December 12, 2018, reversed and remanded. The court found that the ALJ failed to provide sufficient reasons for discounting Macfarlane's testimony, did not adequately explain the residual functional capacity assessment regarding her need to elevate her legs, and improperly evaluated her past work. Critically, the ALJ failed to identify and resolve an apparent conflict between the vocational expert's testimony and the Dictionary of Occupational Titles.

The Ninth Circuit reversed the district court’s judgment and remanded with instructions to remand the case to the Social Security Administration for further administrative proceedings consistent with its opinion.

Whether the Administrative Law Judge properly evaluated the claimant’s residual functional capacity and her ability to perform past relevant work, and whether the judge was required to recognize and resolve an apparent conflict between the vocational expert's testimony and the Dictionary of Occupational Titles.

The ruling reinforced that administrative law judges must provide specific, legitimate reasons backed by substantial evidence when assessing a claimant's residual functional capacity. It clarified the affirmative duty to identify and resolve conflicts between vocational expert testimony and the Dictionary of Occupational Titles, strengthening procedural protections for disability claimants within the Ninth Circuit.