Normandie J. Wiley v. Kenneth S. Apfel, Commissioner Social Security Administration
Docket: 98-2539
Court: Court of Appeals for the Eighth Circuit; March 30, 1999; Federal Appellate Court
The Eighth Circuit Court reversed the decision of the Administrative Law Judge (ALJ) and district court, which had denied Normandie Wiley's application for social security disability and supplemental security income (SSI) benefits. Wiley, a 47-year-old with a high school education, had worked for the Hertz Corporation until an injury in May 1993, which resulted in minimal earnings thereafter. The ALJ determined that although Wiley could not return to her previous jobs, she possessed the functional capacity to perform light work, albeit with significant nonexertional limitations, including an inability to walk or stand for extended periods and to stoop, crouch, or kneel.
On appeal, Wiley argued that the ALJ incorrectly used the grids to assess her ability to find work in the economy, as her nonexertional impairments did not align with the guidelines. The court concurred, noting that vocational testimony was necessary due to the limitations affecting her capabilities. Although a vocational expert categorized her past work as clerical and light exertional, he also indicated she could not return to her previous jobs. The expert's testimony suggested Wiley could perform certain sedentary tasks, but the hypothetical presented to him failed to include her lifting restrictions and inability to stoop, crouch, or kneel, leading to an incomplete assessment. The court remanded the case for further proceedings consistent with its opinion.
The matter is remanded to the Administrative Law Judge (ALJ) with specific instructions to accurately present the hypothetical scenario to the vocational expert and obtain their opinion on the availability of jobs in the regional or national economy suitable for Wiley's limitations, including the number of such jobs. Wiley contends that the ALJ erred by dismissing uncontroverted medical evidence. The medical reports from Dr. Goff, Wiley's treating physician, are ambiguous regarding Wiley's ability to perform sedentary work between May 1993 and January 1995. The ALJ is directed to seek clarification from Dr. Goff on whether there was any continuous twelve-month period during which Wiley could perform sedentary work and her ability to do so as of September 30, 1998. Additionally, the ALJ must reevaluate his determination regarding the credibility of Wiley's pain complaints, considering relevant case law. The conclusion of this review leads to a reversal and remand to the district court, instructing the Commissioner to act in accordance with these findings.
