{"id":429,"date":"2026-01-09T12:00:00","date_gmt":"2026-01-09T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=429"},"modified":"2026-01-09T12:00:00","modified_gmt":"2026-01-09T12:00:00","slug":"karen-jh-bisignano-cd-cal-affirms-ssa-simple-work-reasoning-levels","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=429","title":{"rendered":"Karen J. H. v. Bisignano \u2014 C.D. Cal. Affirms Social Security Denial Where ALJ Reasonably Interpreted Doctor’s ‘Simple Work’ Limitation as Compatible With Routine Reasoning Levels"},"content":{"rendered":"
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Case<\/dt>\n
Karen J. H. v. Bisignano<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Central District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-09<\/dd>\n
Docket No.<\/dt>\n
2:25-cv-06202<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Social Security disability appeal; DOT reasoning levels; medical-source opinion interpretation; substantial evidence; Meissl v. Barnhart<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Plaintiff Karen J. H. sought judicial review of the Social Security Administration’s denial of her disability benefits application. The dispute centered on whether the Administrative Law Judge properly interpreted Dr. Abrahimi’s medical opinion limiting the plaintiff to “simple” work, and whether the alternative jobs identified at step five (which involved Reasoning Level Two, including DOT-rated work like checker, bottling-line attendant, and vacuum tester) were compatible with that limitation.<\/p>\n

The plaintiff argued that “1-2 step routines” (the language Dr. Abrahimi used) corresponded to DOT Reasoning Level One \u2014 meaning the alternative jobs at higher reasoning levels were beyond her capacity. She also argued the ALJ should have explained why she rejected this interpretation of Dr. Abrahimi’s opinion.<\/p>\n

The Court’s Holding<\/h2>\n

Magistrate Judge Karen E. Scott affirmed the Commissioner’s decision. The court explained that the DOT’s Reasoning Level One refers to 1-2 step instructions, not 1-2 step routines \u2014 those are different concepts, and the ALJ correctly noted that “1-2 step routines” are not vocationally defined.<\/p>\n

The court found the ALJ reasonably interpreted Dr. Abrahimi’s opinion as consistent with a limitation to “simple” work compatible with Reasoning Level Two jobs. Plaintiff’s daily activities supported this interpretation: she was capable of driving, reading, caring for her young children, completing household chores, getting her children to school on schedule, using a computer to shop online, paying her own bills, and working part-time as a self-employed hair stylist (a job that, per the DOT, requires Reasoning Level Four). It would be unreasonable to think Dr. Abrahimi meant to limit someone capable of all these activities to Level One reasoning. Dr. Abrahimi himself found Plaintiff had no limitations in the functional area of understanding. Because the ALJ did not reject a medical opinion limiting Plaintiff to Level One reasoning, the ALJ was not required to give reasons for doing so.<\/p>\n

Key Takeaways<\/h2>\n