(SS) Koochou v. Commissioner of Social Security, 2:21-cv-00980-DMC

Plaintiff David Koochou applied for Social Security benefits (application May 1, 2019; alleged onset April 12, 2019); claim denied at initial and reconsideration levels.
ALJ held a Sept. 23, 2020 hearing and issued an Oct. 20, 2020 decision finding severe impairments: right macular retinal detachment (post‑repair), right age‑related cataract (post‑surgical), and right‑eye blindness.
The ALJ assessed an RFC allowing work at all exertional levels but recognized non‑exertional limits from monocular vision; a vocational expert identified several representative jobs existing in significant numbers.
ALJ relied on the Medical‑Vocational Guidelines (section 204.00) and concluded claimant could adjust to other work; Appeals Council denied review.
Plaintiff argued the ALJ misapplied SSR 85‑15 and related POMS guidance on “extremely adverse” vocational profiles tied to visual impairment (e.g., lifetime commitment, limited education).
The magistrate judge affirmed: SSR 85‑15’s listed factors are conjunctive (including a required limited education), claimant had at least a high‑school education, so SSR 85‑15 did not mandate a disability finding; any other errors were harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ erred by failing to apply SSR 85‑15 to find disability based on monocular vision	ALJ should have treated SSR 85‑15 factors as examples; Koochou met most factors (age, no transferable skills, long truck‑driving history) and was properly found to have an "extremely adverse" profile	SSR 85‑15 and POMS are conjunctive; claimant must meet all listed elements (including limited education) to trigger the special finding	Court: SSR 85‑15 requires the listed criteria (including limited education); Koochou had a high‑school education, so SSR 85‑15 did not direct a disability finding
Whether any ALJ error as to other vocational elements (e.g., lifetime commitment length) required remand	Even if ALJ misstated lifetime‑commitment duration or transferability facts, those errors matter only if SSR 85‑15’s required elements were satisfied	Because a required element (limited education) was absent, any other errors were harmless and did not affect the outcome	Court: Any possible errors were harmless; outcome unaffected; affirmed

Tackett v. Apfel, 180 F.3d 1094 (9th Cir. 1999) (standard for substantial evidence review in Social Security cases)
Saelee v. Chater, 94 F.3d 520 (9th Cir. 1996) (definition of "substantial evidence")
Richardson v. Perales, 402 U.S. 389 (1971) (standard for substantial evidence sufficiency)
Thomas v. Barnhart, 278 F.3d 947 (9th Cir. 2002) (deference where evidence supports multiple rational interpretations)
Batson v. Commissioner of Social Security, 359 F.3d 1190 (9th Cir. 2004) (harmless‑error standard in Social Security proceedings)