Hackett v. Barnhart

Hackett (plaintiff) was denied Social Security disability benefits following a hearing before an administrative-law judge (ALJ). The ALJ concluded that Hackett was not disabled because she had the residual functional capacity (RFC) to perform two jobs, which were identified by a vocational expert (VE) who testified at the hearing. Before the VE testified, the ALJ had found that Hackett’s RFC limited her to working jobs that allowed her to avoid direct contact with the general public and only required that she perform simple and repetitive tasks. The VE testified, according to the Dictionary of Occupational Titles (DOT), that the jobs that he identified for Hackett were fairly solitary, only requiring indirect contact with the public via phone and level-three reasoning, requiring an ability to follow written, oral, or diagrammatic instructions and deal with problems with several concrete variables. The VE admitted that Hackett’s RFC did not directly correspond with the job descriptions provided in the DOT; however, he did not provide any explanation for the discrepancies. The ALJ’s denial became the final decision of the Commissioner of the Social Security Administration, Jo Anne Barnhart (defendant). Hackett sought judicial review of the denial in a United States district court. The district court ruled against the commissioner only on the ground that the ALJ failed to reconcile conflicts between the VE’s testimony and the DOT. Barnhart appealed.