Steven Owens v. Carolyn W. Colvin, 727 F.3d 850

Owens applied for Title II disability insurance benefits and Title XVI supplemental security income alleging onset June 25, 2007, based on pain, diverticulitis, and arthritis in multiple joints.
SSA denied initial and reconsideration determinations before Owens requested a hearing.
An ALJ concluded Owens was not disabled and found residual functional capacity enabling past relevant work as inspector/hand packager.
The Appeals Council denied review, making the ALJ's decision the Commissioner’s final decision and the district court affirmed.
The court reverses and remands due to an error in the ALJ’s RFC assessment, specifically the interpretation of “frequent to occasional” handling and fingering.
The district court is instructed to remand to the Commissioner for clarification of Owens’s RFC and further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly defined RFC as ‘frequent to occasional’ handling and fingering.	Owens argues ‘frequent to occasional’ has distinct meanings and cannot be read as a single range.	Commissioner contends the phrase lacks a clear meaning issue but supports the ALJ’s conclusion.	Remanded for RFC clarification due to ambiguity in terms.
Whether the RFC determination precluded past relevant work based on misapprehension of DOT terms.	Dictionary terms show ‘frequently’ and ‘occasionally’ are mutually exclusive; the VE’s testimony lacked clarity.	VE offered testimony consistent with the ALJ’s interpretation; the record supports past work.	Remand to resolve the handling/fingering limitation and its impact on past work.

Brock v. Astrue, 674 F.3d 1062 (8th Cir. 2012) (references five-step evaluation framework and standard procedures at steps)
Hulsey v. Astrue, 622 F.3d 917 (8th Cir. 2010) (substantial evidence review standard applied to disability determinations)