Chavez v. O'Malley, No. 23-1196 (7th Cir. 2024)
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In this appeal before the United States Court of Appeals for the Seventh Circuit, the plaintiff, Kelly Chavez, had been denied supplemental security income due to her various mental and physical impairments. The administrative law judge (ALJ) at a hearing found that Chavez could perform jobs that existed in significant numbers in the economy. This decision was affirmed by the district court, leading to this appeal. Chavez contended that the vocational expert's testimony, which the ALJ relied on, did not provide substantial evidence supporting the ALJ's decision.
The vocational expert, Sarah Holmes, testified that a person with Chavez's age, background, and ability could perform several light exertion jobs, such as cleaner, office helper, and storage rental clerk. She used a software program, Job Browser Pro, to estimate the number of jobs, which uses data from the Bureau of Labor Statistics.
Chavez's main argument was that Holmes did not explain Job Browser Pro's underlying formula, thereby rendering her testimony unreliable. However, the court held that Holmes's testimony provided substantial evidence for the ALJ's finding. The court highlighted that Holmes used a generally accepted source of job numbers, provided a straightforward overview of how the source worked, offered to provide additional information about the source's underlying formula, and identified jobs commonly found in the national economy. Therefore, the court affirmed the district court's judgment.
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