James Terry v. Nancy A. Berryhill, 2:18-cv-08794

Plaintiff James T. applied for Social Security disability benefits alleging onset December 18, 2014; an ALJ held a hearing on August 11, 2017, and issued an unfavorable decision on December 13, 2017.
ALJ found severe impairments: central sleep apnea, left shoulder osteoarthritis, lumbar degenerative disc disease, depression, and anxiety.
ALJ assessed an RFC for medium work with additional restrictions and specifically found Plaintiff could "sit, stand or walk up to 6 hours in an 8 hour workday."
At the hearing the ALJ asked a VE to assume a worker capable of medium work (without expressly restating the 6-hour sit/stand limitation); the VE identified three medium jobs (order filler, packager, laundry worker).
Plaintiff challenged the VE testimony on appeal, arguing the hypothetical was incomplete because it referenced "medium work" rather than expressly stating the RFC’s 6-hour standing/walking limit.
The district court affirmed, finding the ALJ’s reference to medium work implicitly conveyed the 6-hour standing/walking requirement and that reliance on SSR 83-10 was appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the VE testimony constituted substantial evidence that Plaintiff could perform the identified jobs	ALJ’s hypothetical was incomplete because it referenced "medium work" but did not expressly include the RFC’s 6-hour sitting/standing/walking limitation	ALJ’s reference to "medium work" necessarily conveyed the SSA/SSR understanding that medium work requires ~6 hours standing/walking; VE and ALJ would understand that	Court held the hypothetical was adequate; reliance on VE was supported and decision affirmed

Richardson v. Perales, 402 U.S. 389 (establishes substantial-evidence standard for administrative findings)
Han v. Bowen, 882 F.2d 1453 (9th Cir. 1989) (SSR interpretation entitled to deference unless plainly erroneous)
Aukland v. Massanari, 257 F.3d 1033 (9th Cir. 2001) (relied on SSR 83-10 to define sitting/standing/walking requirements)
Macri v. Chater, 93 F.3d 540 (9th Cir. 1996) (endorses SSR 83-10 standards for exertional categories)