Hohman vs. Social Security: Fibromyalgia and Disability Claims

https://docs.google.com/document/d/1Xotm_XZeABYIXIO-8kc6I8rcLiw6gXxo/edit

The case involved Jennifer L. Hohman (plaintiff-appellant) and Kilolo Kijakazi (acting commissioner of social security, defendant-appellee). The ALJ had determined that Hohman had a residual functional capacity for light work, attributing her inability to work primarily to depression and anxiety. The vocational expert's testimony, supporting the availability of 40,000 mail clerk jobs, was backed by substantial evidence.

Hohman had received treatment for anxiety and depression since 1993 and had been diagnosed with fibromyalgia in 2013. Stress was identified as a trigger for her anxiety and depression, exacerbating her fibromyalgia symptoms. In May 2019, Hohman applied for disability benefits, which were denied by the ALJ. The decision was influenced by the vocational expert's testimony, indicating that Hohman could undertake specific jobs still accessible in the job market.

The ALJ concluded that Hohman was capable of light work, which involved tasks not exceeding the lifting of 20 pounds but necessitated walking and standing. Furthermore, the ALJ placed additional physical and social restrictions on Hohman. As per the vocational expert, Hohman could potentially work as a photocopy machine operator, small products assembler, or mail clerk.

Hohman's attorney had objected to the vocational expert's testimony, asserting that it had been too vague. Nonetheless, the ALJ had accepted the vocational expert's testimony, deeming it reliable. On appeal, Hohman argued that the ALJ had failed to acknowledge her testimony regarding the pain and limitations resulting from her fibromyalgia.

The court deliberated on the crucial importance of giving due consideration to disability claims stemming from the impacts of fibromyalgia. It made reference to the Social Security Administration's recognition of the intricate nature of fibromyalgia and the significance of subjective evidence in evaluating a claimant's capacity to work. Ultimately, the court determined that the ALJ had adhered to the guidelines outlined in SSR 12-2P when establishing the light-work RFC for Hohman. Furthermore, it concluded that the ALJ's reliance on the vocational expert's testimony was substantiated by ample evidence.

The court discussed the significance of the vocational expert's (VE) testimony in determining Hohman's ability to work. Reference was made to two cases, Brace v. Saul and Donahue v. Barnhart, to highlight the necessity for the VE's testimony to be substantiated by substantial evidence. The court determined that the VE's testimony in this instance aligned more closely with the Fetting case, where the VE's testimony had substantial evidential support. Hohman's assertion that the VE needed to present precise calculations to validate his estimates was dismissed by the court.

The court examined the VE's employment estimation technique known as the "equal distribution method," which Hohman contended was too vague. Despite the lack of precise data or calculations from the VE, the court deemed his testimony to be reliable. Drawing parallels to Fetting v. Kijakazi and Chavez v. Berryhill, the court emphasized the importance of the VE's testimony being backed by substantial evidence. It was underscored that while the Social Security Administration (SSA) is best positioned to develop a dependable methodology for estimating job figures, such a methodology had not yet been established. The court upheld the ruling of the lower court.