McDonald v. Social Security Administration, 6:14-cv-00220

Claimant Jennifer McDonald (b. 1970) applied for SSDI and SSI in October 2012, alleging disability from August 9, 2012 due to depression/bipolar disorder, arthritis, and back problems.
ALJ held a hearing, received vocational expert (VE) testimony, and found McDonald had the RFC for a reduced range of sedentary, semi‑skilled work with a sit/stand option every 15–20 minutes and no public contact.
ALJ concluded McDonald could not perform past relevant work but could perform three representative jobs (touch‑up screener, suture winder, table worker) existing in significant numbers nationally and regionally; denied benefits on February 27, 2014.
McDonald appealed, arguing at step five the VE’s testimony about job numbers was unreliable because she did not fully document her methodology or production data and the ALJ improperly denied a subpoena for the VE’s source materials.
District court reviewed for substantial evidence and correct legal standards and affirmed the Commissioner, finding the VE’s experience‑based testimony and use of governmental/public sources sufficient to support the ALJ’s step‑five finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reliability of VE job‑numbers testimony at step five	McDonald: VE failed to provide adequate methodology/data; subpoenaed materials should have been produced; thus testimony unreliable	Commissioner: VE identified governmental and public sources and relied on accepted expert methodology and experience; ALJ properly relied on that testimony	Court: VE’s experience‑based testimony and stated sources were sufficiently reliable; ALJ properly credited VE; substantial evidence supports denial of benefits

Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (defines substantial evidence standard)
Consolidated Edison Co. v. NLRB, 305 U.S. 197 (U.S. 1938) (substantial evidence described as more than a scintilla)
Universal Camera Corp. v. NLRB, 340 U.S. 474 (U.S. 1951) (review must consider evidence that detracts from administrative findings)
Trimiar v. Sullivan, 966 F.2d 1326 (10th Cir. 1992) (Commissioner must show work exists in significant numbers at step five)
Channel v. Heckler, 747 F.2d 577 (10th Cir. 1984) (defining "work exists in the national economy")
Ragland v. Shalala, 992 F.2d 1056 (10th Cir. 1993) (need for vocational testimony when grids inapplicable)
Casias v. Secretary of Health & Human Services, 933 F.2d 799 (10th Cir. 1991) (court may not reweigh evidence)
Clifton v. Chater, 79 F.3d 1007 (10th Cir. 1996) (requirement to review the record as a whole)