Joshua Little v. Nancy Berryhill, 708 F. App'x 468

Joshua Little appealed the ALJ’s denial of Child Insurance Benefits and Supplemental Security Income, arguing the RFC assessment improperly handled medical opinion limitations.
Two medical opinions conflicted: Dr. Telford-Tyler limited Little to understanding, remembering, and carrying out simple 1–2 step instructions (Level One reasoning), while another examiner (Moran) limited him to following "simple directions" (Level Two reasoning or less).
The ALJ assigned "great weight" to both opinions but omitted the more restrictive Telford-Tyler 1–2 step limitation in the RFC, instead finding Little could perform "simple work."
The ALJ identified two jobs Little could perform (hospital cleaner and store laborer), both requiring GED Reasoning Level Two, which would conflict with a Level One limitation.
The Ninth Circuit held the ALJ erred by failing to explain the resolution of the conflict between the medical opinions and that the error was not harmless because the omitted limitation would create an apparent conflict with the identified jobs.
The district court’s judgment was reversed and the case remanded for further proceedings consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly considered and resolved conflicting medical-source opinions when assessing RFC	Little argued the ALJ failed to explain rejecting Telford-Tyler’s 1–2 step limitation and thus did not resolve the conflict between medical opinions	Commissioner argued the ALJ reasonably assessed RFC and accorded great weight to medical opinions	Court held ALJ erred by not explaining how he resolved the conflict between Telford-Tyler and Moran opinions
Whether failure to explain the conflict was harmless error	Little argued the omission was not harmless because both identified jobs required higher reasoning than Level One	Commissioner implicitly argued any error was harmless because jobs identified matched RFC as assessed	Court held error was not harmless: identified jobs required Level Two reasoning and thus conflicted with a Level One limitation

Vincent ex rel. Vincent v. Heckler, 739 F.2d 1393 (9th Cir. 1984) (ALJ must explain rejection of significant probative medical evidence)
Terry v. Sullivan, 903 F.2d 1273 (9th Cir. 1990) (DOT is a primary source of reliable job information)
Zavalin v. Colvin, 778 F.3d 842 (9th Cir. 2015) (ALJ must identify specific jobs in substantial numbers consistent with claimant’s RFC)
Rounds v. Comm’r Soc. Sec. Admin., 807 F.3d 996 (9th Cir. 2015) (explains apparent conflicts between RFC limiting to 1–2 step tasks and DOT reasoning levels)
Buck v. Berryhill, 869 F.3d 1040 (9th Cir. 2017) (timing of relevant precedent does not excuse ALJ error; court may proceed to harmless-error analysis)