## Facts

- Tony L. Bladow applied for Title II disability insurance benefits, alleging disability beginning March 15, 1992 due to a back condition with radiating pain and intermittent right-arm weakness.
- The agency denied the claim initially and on reconsideration; Bladow requested an administrative hearing.
- A Functional Capacities Evaluation (Oct. 11–12, 1994) assessed strength, coordination, endurance, and range of motion, concluding Bladow could perform medium work only on a diminished schedule (starting around two hours per day with gradual increase to four) and might tolerate a four-hour workday with gradual increases in a light-duty position.
- A vocational expert (VE), reading the evaluation as limiting Bladow to four hours per day even at light work, testified he could not perform his past relevant manual-labor work.
- The VE testified that if the individual could work six hours per day, jobs such as bench assembler, sorter, or telemarketer existed in large numbers; on cross-examination, the VE stated fewer than half of those jobs were available part-time.
- The ALJ found Bladow not disabled at step five, concluding a significant number of jobs existed that he could perform despite his limitations; the decision became the Commissioner’s final decision.
- The district court granted summary judgment for the Commissioner.

## Issues

1. Whether substantial evidence supported the step-five finding that Bladow could perform other work constituting substantial gainful activity when key evidence and VE interpretation suggested capacity limited to less than full-time work.
2. Whether the ALJ’s reliance on VE testimony based on six- or eight-hour hypotheticals was legally sufficient when the functional evidence indicated a four-hour limitation absent clarification.

## Decision

- The Eighth Circuit reversed the district court’s judgment and remanded to the Commissioner for further proceedings.
- The court held the record did not adequately support the ALJ’s step-five conclusion that Bladow could perform a significant number of jobs on a sustained full-time basis.
- The court required reconsideration and clarification of residual functional capacity (RFC) and vocational evidence, in light of the principle that step-five “other work” generally requires full-time capacity.

## Legal Principles

- At step five, a finding of “not disabled” ordinarily requires an RFC reflecting the ability to perform full-time work (eight hours per day, five days per week, or an equivalent schedule) consistent with substantial gainful activity.
- VE testimony must be based on hypotheticals that accurately reflect the claimant’s medically supported functional limitations; unresolved conflicts between functional assessments and hypotheticals can defeat substantial-evidence support.
- When evidence suggests only part-time capacity, the agency must clarify RFC and whether identified jobs represent full-time work available in significant numbers before denying benefits at step five.

## Conclusion

The Eighth Circuit ordered remand because the ALJ relied on vocational testimony premised on longer workdays without resolving tension between those assumptions and functional evidence indicating a four-hour limitation, leaving the step-five full-time work finding unsupported by substantial evidence.


Bladow v. Apfel, 205 F.3d 356 (8th Cir. 2000)