## Facts

- Kip Yurt applied for Disability Insurance Benefits, alleging disability beginning August 4, 2010, based on severe mental impairments (including a psychotic disorder with hallucinations and rage, and OCD) and physical impairments (including COPD and chronic headaches).
- Yurt previously worked in low-skill jobs such as cook, janitor, and kitchen-related positions.
- In 2010, Yurt experienced serious workplace psychiatric episodes, including being found wandering at work without recollection and later threatening a coworker with a knife, after which he was terminated.
- A state-agency psychologist completed a Mental Residual Functional Capacity assessment finding multiple “moderate” limitations, including in following detailed instructions, maintaining attendance and schedule, sustaining pace and timely completion, and appropriate workplace social interactions.
- An Administrative Law Judge (ALJ) denied benefits, finding Yurt could work at all exertional levels with non-exertional limits framed generally as unskilled tasks, superficial interaction, adequate attention to complete tasks, and avoidance of large groups.
- Relying on a vocational expert’s testimony to that generic hypothetical, the ALJ concluded Yurt could perform past work and other jobs (e.g., industrial janitor, cleaner, towel folder).
- The Appeals Council denied review, and the district court affirmed the denial.

## Issues

1. Whether the ALJ erred by omitting, from the RFC and vocational-expert hypothetical, specific moderate mental limitations reflected in credited medical evidence, particularly limitations in concentration, persistence, and pace and related work-function areas.
2. Whether any omission was harmless because the ALJ limited Yurt to unskilled work with superficial social interaction.

## Decision

- The Seventh Circuit reversed the district court’s judgment and remanded to the agency for further proceedings.
- The court held the ALJ’s RFC and vocational-expert hypothetical were inadequate because they did not meaningfully incorporate, or validly translate into concrete functional restrictions, the moderate limitations identified in the Mental RFC.
- The court rejected harmless error because the missing limitations (e.g., attendance, schedule, pace, timeliness) could change the vocational expert’s job-availability analysis.

## Legal Principles

- When an ALJ credits medical evidence identifying moderate limitations in concentration, persistence, and pace (or closely related work functions), the ALJ must include those limits in the RFC and vocational-expert hypothetical or translate them into specific, work-related functional restrictions with an adequate explanation.
- A restriction to “unskilled work,” “simple, routine tasks,” or similarly generic formulations generally does not capture moderate concentration, persistence, and pace limitations because the ability to do simple tasks differs from the ability to stay on task at an acceptable pace and attendance.
- Vocational-expert testimony is not substantial evidence if the hypothetical question omits material limitations supported by the record and accepted by the ALJ.

## Conclusion

The Seventh Circuit required a remand because the ALJ relied on a vocational-expert hypothetical that did not reflect Yurt’s documented moderate mental-work limitations, so the denial of benefits lacked a reliable evidentiary basis.


Yurt v. Colvin, 758 F.3d 850 (7th Cir. 2014)