Igor Zavalin v. Carolyn W. Colvin

Igor Zavalin appeals the district court’s judgment affirming the Social Security Commissioner’s denial of Supplemental Security Income disability benefits. The administrative law-judge (“ALJ”) found that-Zavalin retains the residual functional capacity to perform simple, routine, or repetitive tasks. The ALJ further concluded that Zavalin is not disabled because he is still able to perform two occupations, namely, cashier and surveillance system monitor. Both of these occupations require the ability to perform Level 3 Reasoning on the Department of Labor’s General Education Development scale, which is defined as the ability to follow written, oral, or diagrammatic instructions and to deal with problems involving several variables from a standardized situation. We hold that there is an apparent conflict between Zavalin’s limitation to simple, routine, or repetitive tasks, on the one hand, and the demands of Level 3 Reasoning, on the other hand. This conflict must be reconciled by the ALJ. Because the ALJ failed to do so, we remand for further proceedings.

BACKGROUND

Zavalin, who was born in Russia, has suffered from severe impairments since childhood. His diagnoses…