## Facts

- Robert M. Haddock applied for Social Security disability benefits, alleging disability beginning in November 1992 based on hip problems and heart and lung-related limitations following a 1992 heart attack.
- An Administrative Law Judge (ALJ) found at step four that Haddock could not perform his past relevant work, including lead carpenter (skilled, heavy) and school janitor (unskilled, medium).
- The ALJ assessed a residual functional capacity (RFC) for sedentary work with an option to alternate sitting and standing, and found Haddock capable of at most semi-skilled work with transferable skills.
- At step five, a vocational expert (VE) identified four jobs the ALJ concluded existed in significant numbers and were within Haddock’s limitations.
- The Dictionary of Occupational Titles (DOT) descriptions for the identified jobs indicated exertional requirements generally greater than the ALJ’s sedentary RFC determination.
- The DOT was not discussed at the hearing, and the ALJ did not ask the VE whether the testimony was consistent with the DOT or request an explanation for any inconsistency.
- The Appeals Council denied review; the district court affirmed the Commissioner’s denial; Haddock appealed.

## Issues

1. Whether VE testimony can constitute substantial evidence at step five when it appears to conflict with the DOT’s job-requirement descriptions and the ALJ does not inquire into or resolve the discrepancy.

## Decision

- The Tenth Circuit reversed the district court’s judgment and remanded for further proceedings.
- The court held that, before relying on VE testimony as substantial evidence at step five, the ALJ must ask how the VE’s testimony corresponds with the DOT regarding exertional requirements.
- The ALJ must obtain a reasonable explanation on the record for any discrepancy between the VE’s testimony and the DOT.

## Legal Principles

- After a claimant shows inability to perform past relevant work, the Commissioner bears the step-five burden to show the claimant can perform other jobs existing in significant numbers in the national economy.
- The DOT is a recognized source of reliable job information in disability adjudications and is a key reference point for job requirements.
- When VE testimony appears inconsistent with the DOT on exertional requirements, the ALJ must identify and resolve the conflict before treating the VE evidence as substantial evidence.
- An ALJ’s duty at step five includes affirmative inquiry into VE–DOT consistency and development of a reasonable explanation for departures from DOT classifications.

## Conclusion

The court required ALJs in step-five determinations to affirmatively ask about and resolve apparent conflicts between VE testimony and the DOT’s exertional job requirements; unexplained inconsistencies prevent VE testimony from constituting substantial evidence supporting a non-disability finding.


Haddock v. Apfel, 196 F.3d 1084 (10th Cir. 1999)