Unreported / Non-Citable
Background
The claimant applied for Supplemental Security Income and was denied after an administrative law judge concluded that he could perform light work. The residual functional capacity assumed he could meet the standing and walking demands associated with that exertional level.
Medical opinions conflicted. Two doctors assessed a six-hour standing or walking capacity, while two others limited the claimant to two hours. The ALJ rejected one two-hour opinion as internally inconsistent and also relied on the claimant’s trip to Hawaii as evidence that he could sustain greater activity.
The Court’s Holding
The district court reversed and remanded because the ALJ misread the medical testimony. The doctor consistently said the claimant could stand or walk for two hours and sit for six hours; his statement about sitting did not contradict the standing-and-walking limitation. An inconsistency squarely contradicted by the record cannot support rejection of a medical opinion.
The Hawaii trip also did not establish the ability to stand or walk for six hours during a workday. Air travel largely involves sitting, and the record did not show how long or far the claimant walked or what accommodations he used. The ALJ further blurred the governing standard by asking whether the claimant could sit, stand, or walk for six hours, while full light work generally requires standing or walking for approximately six hours. The error was consequential because accepting the two-hour limitation could change the residual functional capacity and require different vocational testimony.
Key Takeaways
- An ALJ may not manufacture an internal inconsistency that the medical source’s actual testimony does not contain.
- Light work generally requires standing or walking for about six hours; sitting cannot simply be combined with those activities to satisfy that demand.
- Travel or other daily activity is relevant only when the decision explains how the activity translates into sustained workplace capacity.
- An error is not harmless when proper evaluation could alter the residual functional capacity, vocational evidence, or disability finding.
Why It Matters
The order offers a useful example of the precision required in residual-functional-capacity findings. Small wording differences—standing and walking versus sitting, standing, or walking—can determine whether a claimant fits an exertional category and whether identified jobs remain available.
Claimants and agency counsel should compare the ALJ’s characterization of each opinion with the testimony itself and develop the functional details behind travel or daily activities. On remand, the agency must reassess standing and walking capacity and explain the evidence supporting any new exertional finding.