IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

CONSTANCE SARIESE CANTRELL, § 

Plaintiff, § 

§ 

vs. § CIVIL NO. 4:22-CV-229-P 

§ 

COMMISSIONER OF SOCIAL § 

SECURITY ADMINISTRATION, § 

Defendant. § 

FINDINGS, CONCLUSIONS AND RECOMMENDATION 

OF THE UNITED STATES MAGISTRATE JUDGE AND NOTICE AND ORDER 

This case was referred to the United States Magistrale Judge pursuant to the provisions of 

Title 28, United States Code, Section 636(b). The Findings, Conclusions and Recommendation of 

the United States Magistrale are as follows: 

FINDINGS AND CONCLUSIONS 

I. STATEMENT OF THE CASE 

Plaintiff Constance Sariese Cantrell ("Cantrell") files this action pursuant to Section 205(g) 

of Title 42 of the United States Code for judicial review of a final decision of the Commissioner 

of Social Security denying her disability insurance benefits ("DIB") under Title II of the Social 

Security Act ("SSA"). On July 13, 2020, Cantrell proactively applied for DIB and alleged that her 

disability began November 25, 2019. (Transcript ("Tr.") at 180-81.) Cantrell was initially denied 

on January 12, 2021, and upon reconsideration on March 31, 2021. (Tr. 107-10, 113.) Cantrell 

then requested a hearing before an Administrative Law Judge ("ALJ''). (Tr. 124-25.) A telephone 

hearing was held before the AL.Jon October 20, 2021, and on November 24, 2021, the ALT found 

that Cantrell was not disabled within the meaning of the SSA. (Tr.169-172, 12-14.) The Appeals 

Council denied Cantrell's request for review on March 16, 2022. (Tr. 1-4.) Cantrell filed this civil 

action under 42 U.S.C. § 405(g), requesting judicial review of the AL.J's decision. 

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II. STANDARD OF REVIEW 

Disability insurance is governed by Title II, 42 U.S.C. § 404 et seq., and numerous 

regulatory provisions. See 20 C.F.R. Pt. 404. The SSA defines "disability" as a "medically 

determinable physical or mental impairment" lasting at least twelve months that prevents the 

claimant from engaging in substantial gainful activity. 42 U,S,C. §§ 423(d)(l), 1382c(a)(3)(A). 

To determine whether a claimant is disabled, and thus entitled to disability benefits, a fivestep analysis is employed. 20 C.F.R. § 404.1520(a)(4). First, the claimant must not be presently 

working at any substantial gainful activity. Id. §§ 404.1520(a)(4)(i), (b). "Substantial gainful 

activity" is defined as work activity involving the use of significant physical or mental abilities for 

pay or profit. See id. § 404.1527. Second, the claimant must have an impairment or combination 

of impairments that is severe. Id. §§ 404.1520(a)(4)(ii), (c); see also Slone v. Heckler, 752 F.2d 

1099, 1101 (5th Cir. 1985), cited in Loza v. Apfel, 219 FJd 378, 392 (5th Cir. 2000). Third, 

disability will be found if the impairment or combination of impairments meets or equals an 

impairment listed in the Listing of Impairments ("Listing"). 20 C.F.R. Pt. 404 Subpt. P, App. 1; 

20 C.F.R, § § 404.1520( a)( 4 )(iii), ( d). 1 Fourth, if disability cannot be found based on the claimant's 

medical status alone, the impairment or impairments must prevent the claimant from returning to 

her past relevant work. 20 C.F.R. §§ 404.1520(a)(4)(iv), (f). Fifth, the impairment must prevent 

the claimant from doing any work, considering the claimant's RFC, age, education, and past work 

experiences. Id. §§ 404,1520(a)(4)(v), (g); Crowley v. Apfel, 197 F.3d 194, 197-98 (5th Cir. 

1999). At steps one through four, the burden of proof rests upon the claimant to show she is 

1 Before moving from the third to the fourth step of the inquiry, the Commissioner assesses the claimanfs 

residual functional capacity ("RFC) to determine the most the claimant is able to do notwithstanding her physical 

and mental limitations. 20 C.F.R. §§ 404. I 520(a)(4), (e). The claimant's RFC is used at both the fourth and fifth 

steps of the five-step analysis. Id. § 404. I 520(a)(4). At step four, the claimant's RFC is used to determine if the 

claimant can still do her past relevant work. Id. § 404. l 520(a)(4)(iv). At step five, the claimant's RFC is used to 

determine whether the claimant can adjust to other types of work. Id. § 404. I 520(a)(4)(v). 

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disabled. Crowley, 197 F.3d at 198. If the claimant satisfies this responsibility, the burden shifts 

to the Commissioner to show that there is other gainful employment the claimant is capable of 

performing in spite of her existing impairments. Id. If the Commissioner meets his burden, it is 

up to the claimant to then show that she cannot perform the alternate work. See Carey v. Apfel, 

230 F.3d 131, 135 (5th Cir. 2000). 

A denial of disability benefits is reviewed only to determine whether the Commissioner 

applied the correct legal standards, and whether the decision is supported by substantial evidence 

in the record as a whole. Legge/I v. Chafer, 67 F.3d 558, 564 (5th Cir. 1995); Hollis v. Bowen, 

837 F.2d 1378, 1382 (5th Cir. 1988). Substantial evidence is such relevant evidence as a 

reasonable mind might accept to support a conclusion. Boyd v. Apfel, 239 F.3d 698, 704 (5th Cir. 

2001). It is more than a mere scintilla, but less than a preponderance. Id. A finding of no 

substantial evidence is appropriate only if no credible evidentiary choices or medical findings 

support the decision. Id. ( emphasis added). An ALJ' s decision is not subject to reversal, even if 

there is substantial evidence in the record that would have supported the opposite conclusion, so 

long as substantial evidence suppmis the conclusion that was reached by the ALJ. Dollins v. 

As/rue, No. 4:08-CV-00503-A, 2009 WL 1542466, at *5 (N.D. Tex. Jun. 2, 2009). This Court 

may neither reweigh the evidence in the record, nor substitute its judgment for the 

Commissioner's, but will carefully scrutinize the record to determine if substantial evidence is 

present. Harris v. Apfel, 209 F.3d 413,417 (5th Cir. 2000); Hollis, 837 F.2d at 1383. 

III. ISSUES 

Cantrell presents the following arguments in her brief: 

A. Whether the ALJ properly considered all of Cantrell's functional limitations; 

B. Whether the ALJ properly considered the medical opinion evidence in determining her 

RFC; 

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C. Whether the AL.T properly considered and rejected medical findings in determining 

Cantrell's ability to perform work-related activities; and 

D. Whether the AL.I established the existence of alternative work in significant number that 

Cantrell can perform. 

(Plaintiffs Brief("Pl.'s Br.") at 2-3.) 

IV. ALJ DECISION 

In his November 24, 2021, decision, the ALJ performed the five-step sequential evaluation 

process for determining whether a person is disabled. (Tr. 15-23.) The ALJ first noted that 

Cantrell met the disability insured status requirements under Title II of the SSA through December 

31, 2024. (Tr. 17.) The ALJ then stated that Cantrell had not engaged in substantial gainful activity 

since November 25, 2019, the alleged disability onset date. (Tr. 17.) The ALJ further noted that 

Cantrell had the following "severe" impairments: "epilepsy, depressive disorder, and 

neurocognitive disorder." (Tr. 17.) Next, the ALJ held that none of Cantrell's impairments or 

combination of impairments met or equaled the severity of any impairment in the Listing. (Tr. 

18.) As to Cantrell's RFC, the AL.T stated: 

After careful consideration of the entire record, I find that the claimant has 

the residual functional capacity to perform a full range of work at all exertional 

levels but with the following nonexertional limitations: The claimant can never 

climb ladders, ropes, or scaffolds or operate a motor vehicle in light of her seizure 

potential. The claimant can never work at unprotected heights or with moving 

mechanical parts or otherwise be exposed to unguarded hazard, i.e., there must be 

seizure precautions. She is able to perform simple, routine tasks, and make and 

perform simple work-related decisions. 

(Tr. 19.) Because Cantrell is an individual of advanced age,2 the ALJ stated a "finding regarding 

[her] capacity for past relevant work is not material." (Tr. 22.) The ALJ did find, however, that 

"considering [Cantrell's] age, education, work experience, and residual functional capacity, there 

2 Cantrell was born April 14, 1962, and was 57 years old on the alleged disability onset date. See 20 CFR 

404.1563. 

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are jobs that exist in significant numbers in the national economy that [she] can perform." (Tr. 

22.) Consequently, the ALT found that Cantrell was not disabled. (Tr. 23.) 

V. DISCUSSION 

A. Existence of Alternative Work 

The Court will first address Cantrell's argument that the ALT erred at Step Five. In her brief, 

Cantrell claims that the ALJ erred when he determined without substantial evidence that "past 

relevant work 'is not material"' and that there were jobs that existed in significant numbers in the 

national economy that Cantrell could perform. (Pl. 's Br. at 14-17 .) Specifically, Cantrell 

maintains that the ALJ improperly credited testimony by the vocational expert ("VE") regarding 

job statistics that were insufficiently specific. (Id. at 14-16.) Cantrell argues: 

The VE acknowledged that there is no governmental agency which counts 

jobs by DOT codes. She agreed that jobs are now counted by the Bureau of Labor 

Statistics using the Occupational Employment Statistics (OES) codes, which is the 

same thing as the Standard Occupation Classification (SOC) code. She further 

testified that in responding to the ALJ' s hypothetical question, she identified all of 

the jobs which are contained within the occupational code, as opposed to 

identifying job numbers pursuant to the DOT code. She testified "we don't any 

longer, sadly, have any way to extrapolate from those groupings of jobs how many 

of those numbers exist in each of those jobs." She admitted that the numbers she 

had provided were based upon the total number of jobs in the group. 

[T]he ALJ did not ask the VE to further identify the number of jobs in each of 

the occupational categories which would correspond with the specific jobs which 

the ALJ relied upon in his step 5 determination. Accordingly, there is no evidence 

as to job numbers which can be performed pursuant to the AL.J's hypothetical 

question [to the VE]. As the burden is on the Acting Commissioner to establish the 

existence of work, in significant numbers, which the claimant can perform, the ALJ 

has failed to carry his burden in this instance. 

(Pl. 's Br. at 14-15; 16-17 (internal citations omitted).) 

In response, the Commissioner argues: 

Plaintiff essentially takes issue with the use of data aggregation, arguing in 

essence that if multiple DOT codes map to a single [SOC] Code that has significant 

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positions available, data about the SOC code can provide no useful information 

about how many positions each of the individual DOT codes contributed to the 

total. However, providing relevant information from available vocational resources 

is exactly why VE testimony is obtained in the administrative process. 

The Seventh Circuit has considered a similar argument[] regarding the 

specificity of publications outside of the DOT, such as the Occupational 

employment Quarterly II job numbers, and the court rejected this challenge. More 

recently, the Fourth Circuit addressed this issue, finding that requiring the [VE] to 

produce job statistics specific to the DOT codes means that it is unlikely that the 

Commissioner would ever succeed in satisfying the step five burden - which is not 

the result the regulations intended. 

The VE here relied in part upon data from the Bureau of Labor Statistics, 

one of the sources the Commissioner takes administrative notice ofas a source [of] 

vocational information. Moreover, the VE specifically limited her testimony to the 

medium, unskilled positions she listed as required by the ALJ' s hypothetical 

question, and did not refer to any other exertional and skill level positions that may 

exist within each SOC code, The ALJ could properly rely on the VE's testimony 

as to job numbers at step five. 

(Def.'s Resp, at 16; 17 (internal citations omitted).) 

At Step Five, the Commissioner "must show that there is other substantial work in the 

national economy that the claimant can perform." Aud/er v. As/rue, 501 F.3d 446, 448 (5th Cir. 

2007). When the ALJ cannot rely on the Medical-Vocational Guidelines to determine disability, 

"the ALJ must rely upon expert vocational testimony or other similar evidence to establish that 

such jobs exist." Fraga v. Bowen, 810 F.2d 1296, 1304 (5th Cir. 1987). The AL.! may consult 

various sources of evidence, including VEs and the DOT, to determine alternative and available 

work that the claimant can perform. Veal v. Soc. Sec. Admin., 618 F. Supp. 2d 600,608 (E.D. Tex. 

2009). SSR 00-4p requires the ALJ to identify any apparent conflicts that exist between the VE's 

testimony and the DOT by asking the VE whether such an inconsistency exists. See SSR 00-4p, 

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2000 WL 1898704, at *2 (S.S.A. Dec. 4, 2000); Graves v. Colvin, 837 F.3d 589, 592 (5th Cir. 

2016) (citations omitted). 

At the hearing on October 20, 2021, the ALJ proposed the following hypothetical to the 

VE, which included all of the limitations he found in his RFC determination: 

[ ALJ]: I would like you to assume a hypothetical claimant who does not 

have any past relevant work and does not have a high school diploma. And the 

residual functional capacity for this hypothetical claimant will be as follows with 

non-exertional limits only. Postural limitations would be as follows. This 

hypothetical claimant can never climb ladders, ropes, or scaffolds or operate a 

motor vehicle in light of the seizures potential. 

Environmentally, this claimant can never work at unprotected heights or 

with moving, mechanical parts or otherwise be exposed to unguarded hazards, that 

is there must be seizure precautions. And mental limitations would be in three 

areas. Let me state these affirmatively, is able to perform simple, routine tasks and 

to make - and to perform simple, work-related decisions. Would there be any jobs 

that such a claimant could perform? 

-- Over 55 years of age. 

[VE]: No problem at all, Your Honor. Day worker, DOT code 301.687-

014, unskilled work with an SVP of 2 and medium strength level. And there are 

approximately 73,540 of those jobs existing in the national economy. 

Kitchen helper, DOT code 318.687-010, SVP: 2, medium strength level .. 

. 427, 840 of those jobs estimated to exist nationally. And a third job would be a 

hospital cleaner, that DOT code is 323.687-101, SVP: 2, medium strength level, 

approximately 104,756 of those jobs existing in the national economy. 

[ALI]: Your testimony, is it consistent with the Dictionary of Occupational 

Titles and Selected Characteristics of Occupations? 

[VE]: It is, Your Honor, with the exception of the job numbers, which do 

not exist in those publications. But I have used the Bureau of Labor Statistics 

information and other government publications to come to my estimated job 

numbers. 

(Tr. 46-47.) Cantrell's counsel cross examined the VE on this hypothetical: 

[Mr. Honig]: Okay. Isn't it true that there's no governmental agency that 

counts jobs by DOT codes anymore? 

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[VE]: That's correct. 

[Mr. Honig]: Okay. And isn't it true that jobs arc now counted by the Bureau 

of Labor Statistics using the Occupational Employment Statistics codes, which is 

the same thing as the Standardized Vocational Classification Code? Is that correct? 

[VE]: That is my understanding. Yes. 

[Mr. Honig]: Okay. I see that the total employment for kitchen helper as of 

May of 2020, which is the last number I have, is 395,660 for the entire group. And 

you have 427, 840 for the one job, kitchen helper. So I see a discrepancy there. 

[VE]: Well, yes. And what I failed to mention, Mr. Honig, is ... I also use the 

SkillTRAN compilation estimates, too, in my estimates. 

[VE]: And perhaps I had not updated within the last probably year or so. But 

I don't take exception to your number. And so, even if we go with 395,000 and 

how many jobs are in that group right now, you're looking at -

[Mr. Honig]: Right, but that would be -

[VE]: --because - and it doesn't matter, but -

[Mr. Honig]: - the entire group. 

[VE]: The other issue, of course, is we don't any longer, sadly, have any way 

to extrapolate from those groupings of jobs how many of those numbers exist in 

each of those jobs. So, I think we can agree that job numbers now are kind of 

sometimes in a gray area, if you will. Go ahead. 

[Mr. Honig]: Okay, understood. So, are you telling me that your testimony 

was based upon the group? Is that correct? The numbers you -

[VE]: I believe, yes. 

(Tr. 48-50.) 

The SOC is "[m]uch like the Census Code system, it is 'used by Federal statistical agencies 

to classify workers into occupational categories for the purpose of collecting, calculating, or 

disseminating data,"' Vandermark v. Colvin, No. 3: l 3-cv-l 467, 20 l 5 WL l 097391, at * 12 

(N.D.N. Y. March l l, 20 l 5) (citing Bureau of Labor Statistics, "Standard Occupational 

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Classification," available at http:// www.bls.gov/soc/ (last visited on Feb. 22, 2023)). It is 

apparent, and, here, not contested by the Commissioner, that there is no individual numerical data 

for specific DOT codes within the SOC. As such, the number of jobs reported by the SOC docs 

not provide the specific number of jobs for any specific DOT code. See Boston v. Colvin, No. 

4:14-CV-206-D, 2016 WL 721563, at *11 (E.D.N.C. Feb. 2, 2016). At the hearing, the VE 

acknowledged this grouping during cross-examination. (Tr. 49-50.) "Further, the DOT 

occupations included within a given Census code do not necessarily have the same skill and 

cxertional requirements." Id. (citing Vandermark, 2015 WL 1097391 at * 12 ("SOC codes 

encompass a broad grouping of jobs, and do not contain the same detailed occupational 

information (position descriptions) as DOT codes. Hence, one cannot infer that every job within 

a given SOC code has the same skill and exertional requirements, nor can one determine the 

incidence of available jobs for a single occupation within that code.")). 

While the Fifth Circuit has not addressed this issue, other courts have upheld as substantial 

evidence an ALJ's reliance on a VE's proposed job numbers derived from SOC data when the VE 

"further adjusts the number ofjobs in the broader [] category to a number that reflects the number 

of jobs for the cited DOT occupation and provides a reasonable basis for having done so." Boston, 

2016 WL 721563 at *11; see also Vandermark, 2015 WL 1097391, at *16 (citing multiple cases 

that illustrate that, "despite the lack of specificity of the [I incidence data, it is possible for a VE to 

make a reasonable adjustment to reflect DOT-specific job numbers by calling on other available 

sources as well as professional experience."); Daniels v. Colvin, No. CV 13-654 MRW, 2014 WL 

794498, at *4 (C.D. Cal. 26 Feb. 2014) ("The analytical structure that the Social Security 

Administration ["SSA"] employs to extrapolate that information-[VEs] actively interpreting job 

data obtained from reputable government or private industry sources-can certainly satisfy the 

undemanding 'substantial evidence' standard applied in Social Security cases."). However, it is 

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problematic when a VE fails to "reasonably adjust" or to "make any adjustments at all in the 

number of jobs reported [] for a Census code to reflect the number of jobs for a specific DOT job 

included within that Census code." Boston, 2016 WL 721563 at *12. It is even more problematic 

when the other DOT jobs included in the Census code are not jobs that the particular plaintiff may 

perform with his assigned RFC. Id. 

As set forth above, at issue is whether the ALJ relied on substantial evidence presented by 

the VE when determining there was a significant number of jobs in the national economy that 

Cantrell could perform pursuant to her assigned RFC. (Pl.'s Br. at 15.) Upon receiving the 

hypothetical, the VE testified that Cantrell could perform work as a day worker, a kitchen helper, 

and a hospital cleaner. (Tr. 47.) All three jobs maintain an SVP of 2, medium strength level, and 

are within Cantrell's assigned RFC. The ALJ did not inquire of the VE how she obtained these 

numbers, rather, he merely asked the VE if her testimony was "consistent with the [DOT] and 

selected characteristics of occupations." (Tr. 4 7.) The VE stated her testimony was consistent 

with the DOT and selected characteristics of occupations "[b]ut that [she has] used the Bureau of 

Labor Statistics information and other government publications to come to [her] estimated job 

numbers." (Tr. 47.) The ALJ posed no farther questions to the VE. On cross-examination, when 

asked about the number of jobs available in the national economy, the VE revealed she "also use 

the SkillTran complication estimates" in formulating the numbers. (Tr. 49.) 

The VE's testimony did not provide the ALJ with substantial evidence on the number of 

jobs available for Cantrell in the national economy. While the three jobs provided by the VE~ 

day worker, kitchen helper, hospital cleaner~are within Cantrell's assigned RFC, the VE did not 

testify that she made any reasonable adjustment to reflect DOT-specific job numbers by calling on 

other available sources or professional experience. See Daniels, 2014 WL 794498, at *2 ('The 

expert did not expressly indicate that she relied on any professional knowledge or experience to 

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evaluate this information. Rather, it appears that she took the 'aggregate number with a certain 

number of occupations.'"). And, while the VE states that she compiled numbers, the record does 

not support a finding that she actively interpreted job data in a manner that validates the ALJ's 

requisite "substantial evidence" standard. Instead, the VE testified that "job numbers now are kind 

of sometimes in a gray area," and that she had not reviewed certain estimates "within the last 

probably year or so." (Tr. 49, 50.) Moreover, the ALJ also failed to elicit any testimony from the 

VE that could plausibly establish the relationship between Cantrell's ability to perform a DOT 

listed job and the number of those positions in Texas or throughout the United States. 

Based on the foregoing, and after careful review of the record, the Court FINDS the VE's 

testimony did not provide the ALJ with substantial evidence and that the ALJ failed to carry its 

burden of proof to establish the existence of alternative work, in significant numbers, which 

Cantrell can perform. See Daniels, 2014 WL 794498, at *4 ("The Court concludes that no 

'reasonable mind might accept as adequate' the minimal showing on offer here.") 

RECOMMENDATION 

For the foregoing reasons, the Court RECOMMENDS that the ALJ's decision be 

VACATED and that the case be REMANDED to the agency for further proceedings.3 

NOTICE OF RIGHT TO OBJECT TO PROPOSED 

FINDINGS, CONCLUSIONS AND RECOMMENDATION 

AND CONSEQUENCES OF FAILURE TO OBJECT 

Under 28 U .S.C. § 636(b )(I), each party to this action has the right to serve and file specific 

written objections in the United States District Court to the United States Magistrate Judge's 

proposed findings, conclusions, and recommendation within fourteen (14) days after the party has 

been served with a copy of this document. The United States District Judge need only make a de 

3 As the Court is recommending remand, it wil! not address Cantrell's three remaining issues. If the District 

Judge does not agree and accept the recommendation of remand, the undersigned ,vi!\ address the remaining three 

issues. 

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novo determination of those portions of the United States Magistrate Judge's proposed findings, 

conclusions, and recommendations to which specific objection is timely made. See 28 U.S.C. 

§ 636(b)(l). Failure to file by the date stated above a specific written objection to a proposed 

factual finding or legal conclusion will bar a party, except upon grounds of plain error or manifest 

injustice, from attacking on appeal any such proposed factual findings and legal conclusions 

accepted by the United States District Judge. See Douglass v. Unired Services Aura Ass 'n, 79 F.3d 

1415, 1428-29 (5th Cir. 1996) (en bane). 

ORDER 

Under 28 U.S.C. § 636, it is hereby ORDERED that each party is granted until March 14, 

2023, to serve and file written objections to the United States Magistrate Judge's proposed 

findings, conclusions and recommendation. It is further ORDERED that if objections are filed 

and the opposing party chooses to file a response, the response shall be filed within seven (7) days 

of the filing date of the objections. 

It is fmiher ORDERED that the above-styled and numbered action, previously referred to 

the United States Magistrate Judge for findings, conclusions, and recommendation, be and hereby 

is returned to the docket of the United States Distri"'ct,.......""6 

SIGNED February 28, 2023. 

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