Rachel Goode v. Commissioner of Social Security, 966 F.3d 1277

Rachel Goode applied for Social Security disability benefits after a 2011 vehicle accident that ended her nursing career; an ALJ denied benefits at step five of the sequential evaluation based on vocational-expert (VE) testimony.
At the hearing a VE testified (by phone) that the DOT-listed job "bakery worker" (DOT No. 524.687-022) had ~43,000 national and ~1,000 regional jobs and thus was available in significant numbers.
The VE admitted using OEQ/OES and SOC groupings to derive job counts but mapped the bakery-worker DOT code to SOC 51-3099 (Food Processing Workers, All Other) rather than the correct SOC 51-9199 (Production Workers, All Other).
The VE did not allocate the SOC-group totals among the multiple DOT occupations contained in that SOC group or otherwise explain how the SOC totals translated into job counts specifically for bakery worker.
The ALJ adopted the VE testimony as uncontradicted and denied benefits; the Appeals Council denied review and the district court affirmed. The Eleventh Circuit reversed and remanded, finding the VE testimony materially flawed and the record lacking substantial evidence on step five.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substantial evidence supports the ALJ's step-five finding that there are a significant number of jobs Goode can perform	Goode: VE testimony unreliable—VE used wrong SOC mapping and overstated job numbers without methodology to apportion SOC totals to the DOT job	Commissioner: VE explained methodology; claimant failed to adequately develop or repeatedly challenge VE at hearing; ALJ properly relied on VE	Reversed and remanded: VE used incorrect SOC code for the DOT bakery-worker occupation and failed to apportion SOC-group totals to the single DOT job, so VE testimony did not supply substantial evidence for step five.

Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (vocational-expert testimony evaluated case-by-case; no categorical rule requiring disclosure of underlying data)
Chavez v. Berryhill, 895 F.3d 962 (7th Cir. 2018) (criticizes DOT–SOC matching problems and the use of SOC totals without reasonable allocation)
Brault v. Soc. Sec. Admin., 683 F.3d 443 (2d Cir. 2012) (discusses information loss in mapping DOT to SOC and need for methodological support)
Purdy v. Berryhill, 887 F.3d 7 (1st Cir. 2018) (describes occupational-density methods such as JobBrowser Pro for allocating SOC totals)
Hale v. Bowen, 831 F.2d 1007 (11th Cir. 1987) (Commissioner must show jobs exist in national economy the claimant can perform at step five)
Washington v. Comm’r of Soc. Sec., 906 F.3d 1353 (11th Cir. 2018) (ALJs may rely on both DOT and VE testimony at step five)
Britton v. Astrue, 521 F.3d 799 (7th Cir. 2008) (vocational-expert testimony lacking methodological support may fail the substantial-evidence threshold)