Angela Lawrence v. Andrew Saul, 941 F.3d 140

Angela Lawrence applied for Social Security disability benefits in January 2013; SSA denied benefits and an ALJ held a hearing.
The ALJ found Lawrence could do "simple, routine, repetitive tasks of unskilled work" (RFC) and therefore could not return to her prior, more demanding MetLife management job.
At step five the ALJ relied on a vocational expert (VE) who identified three representative jobs (folder, classifier, router) that exist in significant numbers nationally.
The DOT lists those jobs as requiring Level 2 reasoning ("detailed but uninvolved instructions" and "few concrete variables"); the VE testified his testimony was consistent with the DOT.
Lawrence argued on appeal that the RFC limiting her to "simple, routine, repetitive tasks" conflicts with DOT Level 2 reasoning and asked for remand; the district court and the Fourth Circuit rejected the claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an RFC limiting Lawrence to "simple, routine, repetitive tasks" creates an apparent conflict with DOT Level 2 reasoning for the jobs the VE identified	Lawrence: "simple, routine, repetitive tasks" is inconsistent with DOT Level 2's requirement to follow "detailed" instructions, so the ALJ had to resolve the conflict and remand	Commissioner: No apparent conflict; the VE said his testimony was consistent with the DOT and the RFC does not preclude Level 2 reasoning	The Fourth Circuit held there is no apparent conflict and affirmed the denial of benefits

Thomas v. Berryhill, 916 F.3d 307 (4th Cir. 2019) (explaining ALJ duty to identify and resolve apparent conflicts between VE testimony and the DOT)
Pearson v. Colvin, 810 F.3d 204 (4th Cir. 2015) (comparing DOT language to VE testimony to assess apparent conflicts)
Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015) (describing the five-step SSA disability evaluation framework)
Moore v. Astrue, 623 F.3d 599 (8th Cir. 2010) (construing "simple" and "uninvolved" as compatible terms)