Brooke Taskila v. Comm'r of Social Security, 819 F.3d 902

Plaintiff Brooke Taskila, age 37, applied for Social Security disability insurance and SSI claiming chronic pain, mental symptoms, memory problems, incontinence, and carpal tunnel following multiple car accidents and medical treatment (including breast mass treatment and knee pain).
Initial examiner denied benefits; an ALJ after a hearing found Taskila could perform a modified range of sedentary, unskilled work; the Appeals Council denied review and the district court affirmed.
ALJ discounted Taskila’s subjective daily-activity limitations based on medical records and an evaluator’s report showing she functioned reasonably (walked 45 minutes, maintained a B average at university, socialized, had interests).
A vocational expert testified that Taskila could work as a callout operator or system surveillance monitor, totaling about 200 jobs in Michigan and 6,000 nationally.
ALJ concluded these jobs exist in significant numbers and denied benefits; the Sixth Circuit reviewed for substantial evidence and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ’s credibility/RFC findings were supported by substantial evidence	Taskila argued ALJ improperly discredited her testimony about severe daily limitations	ALJ relied on medical records and an evaluator showing greater functionality to limit, not eliminate, work ability	Held: ALJ’s credibility determination and RFC are supported by substantial evidence
Whether 6,000 national jobs are a "significant number"	Taskila argued 6,000 jobs nationwide are not significant enough to deny benefits	Commissioner pointed to precedent treating numbers like 2,000+ as significant and VE testimony supporting availability	Held: 6,000 jobs is significant; caselaw supports finding such numbers sufficient
Whether the "significant numbers" question is legal or factual	Taskila treated it as a legal/statutory question requiring bright-line rule	Commissioner treated it as a fact-intensive, claimant-specific inquiry reviewed for substantial evidence	Held: It is a fact question (claimant-specific) reviewed under substantial-evidence standard
Whether ALJ violated SSA internal guidance by citing only two occupations (POMS requires three)	Taskila argued ALJ must cite three occupations per POMS	Commissioner noted POMS permits fewer than three when clear jobs exist and regs allow reliance on VE	Held: No procedural violation; POMS allows citing fewer than three when appropriate

Sims v. Apfel, 530 U.S. 103 (U.S. 2000) (Appeals Council denial makes ALJ decision final)
Smith v. Comm’r of Soc. Sec., 482 F.3d 873 (6th Cir. 2007) (standard of review: substantial evidence for factual findings)
Miller v. Comm’r of Soc. Sec., 811 F.3d 825 (6th Cir. 2016) (agency legal interpretations reviewed de novo)
Barnhart v. Walton, 535 U.S. 212 (U.S. 2002) (statutory framework for disability evaluation)
Barnhart v. Thomas, 540 U.S. 20 (U.S. 2003) (five-step sequential evaluation process)
Hall v. Bowen, 837 F.2d 272 (6th Cir. 1988) (factors ALJs should consider in determining whether work exists in significant numbers)
Harmon v. Apfel, 168 F.3d 289 (6th Cir. 1999) (disability not excused by claimant living far from job; consider intrinsic limits)
Kerner v. Flemming, 283 F.2d 916 (2d Cir. 1960) (historical approach to claimant-specific employment availability inquiry)
Liskowitz v. Astrue, 559 F.3d 736 (7th Cir. 2009) (collecting cases on thresholds for "significant" numbers)
Jenkins v. Bowen, 861 F.2d 1083 (8th Cir. 1988) (cases treating several hundred jobs as significant)
Barker v. Sec’y of Health & Human Servs., 882 F.2d 1474 (9th Cir. 1989) (numbers-based significant-jobs precedent)