Seals v. Saul, 1:18-cv-07738

Seals applied for SSI (filed Dec. 2, 2014) alleging PTSD, knee pain, and hypertension; agency psychiatric consultants found moderate limitations in concentration, persistence, and pace (CPP).
Initial and reconsideration denials; ALJ held a hearing, elicited VE testimony based on a hypothetical limiting claimant to light, simple, routine, repetitive tasks with no production-rate pace or tandem tasks.
VE identified ~167,000 national jobs (e.g., shipping weigher, inspector); ALJ gave great weight to agency psychiatric consultants, adopted an RFC allowing those jobs, and found Seals not disabled.
Appeals Council denied review; Seals filed suit in district court challenging the step-five finding and the adequacy of the VE hypothetical.
District court held the ALJ erred by failing to account for Seals’s documented moderate CPP limitations in the RFC/hypothetical and remanded because the VE record did not independently support the omitted limitations or show the impact on job availability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ’s hypothetical and RFC adequately accounted for Seals’s moderate limitations in concentration, persistence, and pace (CPP)	ALJ’s hypothetical (simple, routine, repetitive tasks; no production-rate pace) did not capture documented moderate CPP limits and so the VE testimony is unreliable	Hypothetical was adequate; limitations like "no production-rate pace" and "simple, routine" work capture CPP limits and the ALJ gave great weight to psychiatric consultants	Court held the hypothetical and RFC were inadequate because the ALJ failed to build a logical bridge from the documented moderate CPP limitations to the limitations posed to the VE; remand required
Whether any error was harmless (i.e., VE would have identified same jobs even if CPP limitations were included)	Error not harmless because record does not show what VE would have said if properly asked or that the VE independently reviewed the file	Argues possible harmlessness; points to similar formulations in other decisions	Court rejected harmless-error defense: record is not detailed enough to conclude the VE would have identified the same jobs; remand required

Winsted v. Berryhill, 923 F.3d 472 (7th Cir. 2019) (VE hypothetical must account for documented CPP limitations unless VE independently reviewed the record)
Moreno v. Berryhill, 882 F.3d 722 (7th Cir. 2018) (limiting to simple, routine tasks does not automatically capture moderate CPP limitations)
DeCamp v. Berryhill, 916 F.3d 671 (7th Cir. 2019) (excluding fast production or tandem tasks is not a reliable proxy for moderate CPP limits)
Crump v. Saul, 932 F.3d 567 (7th Cir. 2019) (ability to perform simple tasks does not show ability to sustain them through a full workday)
O'Connor-Spinner v. Astrue, 627 F.3d 614 (7th Cir. 2010) (distinguishing task complexity from sustained persistence and pace; hypothetical must reflect CPP limits)
Yurt v. Colvin, 758 F.3d 850 (7th Cir. 2014) (RFC/hypothetical must capture the claimant’s particular CPP limitations or explain how the hypothetical excludes triggering conditions)
Josefyk v. Berryhill, 923 F.3d 492 (7th Cir. 2019) (ALJ’s hypothetical may suffice in limited circumstances when CPP limits arise only in specific settings and the hypothetical captures those settings)
Varga v. Colvin, 794 F.3d 809 (7th Cir. 2015) (explains standards for RFC and necessity to include limitations supported by the record)