Cynthia Coleman v. Michael Astrue

MEMORANDUM

Cynthia Coleman seeks disability insurance benefits from the Commissioner of Social Security (“Commissioner”). The administrative law judge (“ALJ”) determined that Coleman has the residual functional capacity to perform sedentary or light work, so long as she can switch between sitting, standing, and walking at least briefly every hour. Based on testimony provided by a vocational expert (“VE”) that Coleman could perform three specified occupations, the ALJ then held that Coleman could perform work that exists in significant numbers in the economy. He therefore denied benefits.

Coleman filed suit in district court, contending that the ALJ erred in two ways. First, Coleman faulted the ALJ for disbelieving her testimony of severe pain on the grounds that her fibromyalgia did not result in certain physical symptoms and that Coleman failed to lose weight as treatment for her obesity. Second, Coleman argued that the ALJ violated Social Security Ruling (“SSR”) 00-4p by failing to ask the VE whether the VE’s testimony conflicted with the Dictionary of Occupational Titles (“DOT ”). The district court held that any errors committed by the ALJ were harmless.

1. The ALJ relied…