By: WISCONSIN LAW JOURNAL STAFF//July 3, 2023//
7th Circuit Court of Appeals
Case Name: Jennifer Hohman v. Kilolo Kijakazi
Case No.: 22-2831
Officials: Scudder, St. Eve, and Kirsch, Circuit Judges.
Focus: Social Security Benefits Application
After Hohman, aged 53, applied for Social Security benefits due to her inability to work, a vocational expert testified that despite her limitations caused by fibromyalgia, PTSD, depression, and anxiety, she could still perform jobs such as a photocopy machine operator, small products assembler, or mail clerk. Based on this testimony, an Administrative Law Judge (ALJ) denied Hohman’s claim for benefits, concluding that there were significant numbers of light work jobs available in the current economy that she could perform with her limitations. The vocational expert explained that he used a “weighted estimate” method to determine job availability based on his extensive professional experience and labor market surveys. Hohman expressed concerns about the method’s reliability, but the Seventh Circuit and the district court affirmed the denial, stating that substantial evidence supported the decision. The courts acknowledged Hohman’s frustrations but held that the ALJ’s reliance on the equal distribution method alone was not reversible error. Affirmed.
Decided 06/28/23