Yurt v. Colvin

Kip Yurt (plaintiff) applied for Social Security disability benefits, claiming that he was unable to work due to a combination of physical and mental impairments. Following a hearing, an administrative-law judge (ALJ) concluded that Yurt was not disabled because he had the residual functional capacity (RFC) to perform a full range of work at all exertional levels so long as he had only superficial interactions with others and was not around large groups of people. The ALJ based her RFC determination largely on an administrative psychologist’s mental RFC assessment in which the psychologist found that Yurt had moderate limitations in his ability to understand, remember, and carry out detailed instructions; perform activities on schedule and maintain regular attendance; perform at a consistent pace and timely complete work; interact appropriately with the general public; get along with coworkers; and maintain socially appropriate behavior. The expert concluded that although Yurt’s diagnosis was consistent with severe impairment, he could still perform unskilled work with relation to others at least on a superficial level. Despite reliance on the psychologist’s mental RFC assessment, to assess what jobs Yurt could still perform the ALJ posed a hypothetical to a vocational expert describing an individual that can remember and carry out unskilled tasks without special considerations, relate at least on a superficial level with others, attend to tasks enough to complete them, and who should not work around large groups of people. Based on the hypothetical, the expert opined that Yurt could perform his past work as a dishwasher, janitor, and kitchen helper. The ALJ concluded that Yurt had the RFC to perform work as an industrial janitor, cleaner, or towel folder. The ALJ’s decision became the final decision of the Commissioner of the Social Security Administration, Carolyn Colvin (defendant). Yurt sought judicial review of the decision, and a United States district court affirmed the decision. Yurt appealed.