U.S. Court of Appeals for the Fourth Circuit, 2015

The Fourth Circuit held that an ALJ must independently identify apparent conflicts between vocational-expert testimony and the Dictionary of Occupational Titles, even when the expert says there is no conflict.

The court reversed the district court’s judgment upholding the denial of benefits and remanded for further administrative proceedings. It held that the ALJ’s unexplained failure to analyze relevant functions, address how Mascio’s moderate concentration, persistence, or pace limitation affected her work capacity, and…

The court held that the record, viewed in Jacobs’s favor, presents genuine disputes of material fact on her ADA disability-discrimination, retaliation, and failure-to-accommodate claims, so summary judgment on those claims was improper.