Rounds v. Commissioner Social Security Administration

Appellant Heather Rounds appeals from the district court’s affirmance of the decision of a Social Security Administration Administrative Law Judge (ALJ) denying her application for Supplemental Security Income (SSI). Although we find no error in the ALJ’s rulings on several issues, we vacate in part and remand because the ALJ failed to reconcile an apparent conflict between a vocational expert’s (VE) testimony and the Dictionary of Occupational Titles.

BACKGROUND

I. Rounds’ Self-Reported Activities and Limitations

At the time of her SSI application, Rounds was 22 years old, a high school graduate, and the mother of a five-year-old daughter. She was living with her daughter, a roommate/boyfriend named Gavin Lipscomb, and her two cats. In the function report accompanying her application, Rounds described difficulties with social interactions, leaving the house, sleeping, remembering to eat and care for herself, and remembering instructions. Nevertheless, she stated that she was able to care for her daughter and her cats, prepare simple meals, share house work with her roommate, shop for groceries, and pay bills. Lipscomb submitted a third-party function report that…