When Vocational Testimony Skips the Overhead-Reaching Conflict
A federal court in North Carolina has ordered a new round of proceedings in a Social Security Disability Insurance case after finding that the Administrative Law Judge did not adequately address a conflict between the claimant’s reaching limitations and the jobs identified at step five.
In Aida L.F. v. Frank Bisignano, the claimant sought Title II Disability Insurance Benefits, alleging disability beginning October 29, 2021. After a February 12, 2024 hearing, the ALJ found her not disabled. The Appeals Council denied review on February 24, 2025, making the ALJ’s decision the Commissioner’s final decision.
The dispute centered on the claimant’s residual functional capacity, or RFC. The ALJ found that she could reach frequently with both arms but could perform overhead reaching and overhead weight-bearing only occasionally on both sides. Those restrictions mattered because, at step five, the Commissioner bore the burden of identifying work the claimant could still perform.
The vocational expert identified four jobs: marker, photocopy machine operator, non-postal mail clerk, and router. According to the Dictionary of Occupational Titles, each requires frequent reaching. But the DOT’s broad description of “reaching” does not distinguish among directions, including overhead reaching.
That creates an important issue under the Fourth Circuit’s decision in Pearson v. Colvin. When an RFC limits overhead reaching but a proposed job calls for frequent reaching, an apparent conflict may exist. The ALJ must recognize that conflict, ask the vocational expert about it, and obtain a reasonable explanation before relying on the testimony.
Here, the ALJ asked only a general question about limitations not addressed by the DOT or its companion publication. The vocational expert responded generally that the testimony was based on education and experience. The court concluded that this exchange did not identify or resolve the specific conflict involving occasional overhead reaching.
That distinction is significant for disability claimants. A vocational expert’s testimony is not automatically sufficient merely because the ALJ asks whether it is consistent with the DOT. When the testimony and the DOT appear to pull in different directions, the record needs an explanation tied to the actual limitation and the actual jobs at issue.
The court reversed the Commissioner’s no-disability decision and remanded the case under sentence four of 42 U.S.C. § 405(g) for further proceedings. A remand is not an award of benefits. It gives the agency another opportunity to evaluate the step-five evidence under the governing standards.
The court applied Social Security Ruling 00-4p because it was in effect when the ALJ issued the 2024 decision. SSR 00-4p has since been prospectively rescinded by SSR 24-3p, so the governing framework may differ for newer agency decisions. Even so, Aida L.F. illustrates an enduring point: vocational evidence must meaningfully account for the limitations the ALJ places in the RFC.
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Case: Aida L.F. v. Bisignano, No. 1:25CV300, 2026 U.S. Dist. LEXIS 215336, 2026 WL 2824358 (M.D.N.C. Sept. 21, 2026).
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