Podunajec v. Saul

7 Citing cases

  1. Soto v. Kijakazi

    Civil Action 4:21-CV-1531 (M.D. Pa. Sep. 20, 2022)

    While this alone is enough to establish that this error cannot be harmless, the Court in Beltran provides more specific reasoning. The Beltran decision collects cases from several districts and circuits to show that when a limitation to “one or two step tasks” is erroneously omitted from a residual functional capacity and/or hypothetical question to the vocational expert, such an error is harmful. See also Podunajec v. Saul, Civ. A. No. 3:19-cv01938-JFS at *16 (M.D. Pa. Dec. 11, 2020); Hurrey v. Colvin, 1:14-CV02408, slip op. at 19-21 (M.D. Pa. Jan. 28, 2016) (Report & Recommendation) (finding that omission of a limitation to 1-2 step tasks could potentially impact a VE's testimony and the ALJ's ultimate conclusion), adopted, 1:14-CV-02408, slip op. (M.D. Pa. Feb. 2, 2016) (Order); Harden v. Commissioner of Social Security, No. 13-906, 2014 WL 4792294, at *3-5 (W.D. Pa. Sept. 24, 2014) (finding that “a limitation regarding the complexity of tasks and instructions that a claimant can perform may be different from a limitation regarding the routineness or repetitiveness of a job.”); McGriff v. Colvin, No. 3:16-CV-911, 2017 WL 3142336, at *3 (D. Conn. July 25, 2017) (collecting cases).

  2. Pokorny v. Kijakazi

    Civil 1:21-CV-00790 (M.D. Pa. Oct. 23, 2023)

    According to Pokorny, this court has found that such an error is always harmful. Id. (citing, e.g., Beltran v. Berryhill, Civ. A. 3:17-cv-00715-SES (M.D. Pa. Feb. 20, 2018); Podunajec v. Saul, Civ. A. No. 3:19-cv-01938-JFS at *16 (M.D. Pa. Dec. 11, 2020); Hurrey v. Colvin, 1:14-CV-02408, slip op. at 19-21 (M.D. Pa. Jan. 28, 2016)).

  3. Edwards v. Kijakazi

    Civil Action 21-cv-1429 (E.D. Pa. Sep. 29, 2023)   Cited 1 times

    Although the distinction between an RFC for simple, routine tasks as opposed to one and two-step tasks is unsettled in the Third Circuit, many district courts have decided there is a distinction, and the distinction is meaningful. See e.g., Stine, 2023 WL 3483885, at *9 (citing cases); Podunajec v. Saul, No. 3:19-cv-01938, 2020 WL 7319779, at *6 (M.D. Pa. Dec. 11, 2020) (noting significant difference between RFC with limitation to one and two-step tasks and RFC with limitation to simple, routine tasks and remanding when ALJ erred by not including one-and two-step tasks in RFC); Beltran v. Berryhill, 3:17-cv-00715, slip. op. at 2 (M.D. Pa. Feb. 20, 2018) (“there is a significant and now well-acknowledged difference between an RFC limitation to one-to-two step tasks and an RFC limitation to short, simple instructions.”)

  4. Christopher J v. Kijakazi

    Civil Action 4:22-CV-497 (M.D. Pa. Sep. 27, 2023)

    Stine v. Kijakazi, Civ. No. 21-5492, 2023 WL 3483885 at *9 (E.D. Pa. May 15, 2023) (citing Maher v. Saul, Civ. No. 19-5721, 2020 WL 5876808, at *5 (E.D. Pa. Sept. 9, 2020) (limitation to “simple, routine, repetitive tasks” is not the same as more restrictive limitation to “one- and two-step tasks”) report and recommendation adopted 2020 WL 5849466 (E.D. Pa. Oct. 1, 2020) and Podunajec v. Saul, Civ. No. 19-1938, 2020 WL 7319779, at *6 (M.D. Pa. Dec. 11, 2020) (“[T]he Court finds that there is a significant difference between an RFC limitation to one and two step tasks and an RFC limitation to simple routine tasks.”).

  5. Shipman v. Kizakazi

    Civil Action 3:22-CV-00636 (M.D. Pa. Aug. 29, 2023)

    In Podunajec v. Saul, the Court found that an ALJ's failure to explain why a one- or two-step task limitation was omitted from the RFC assessment required a remand. No. 3:19-CV-01938, 2020 WL 7319779, at *6-7 (M.D. Pa. Dec. 11, 2020). In Podunajec, the ALJ gave great weight to one medical opinion which opined that the claimant could “understand, retain, and follow simple job instructions (i.e. perform/follow one and two step tasks/instructions).” 2020 WL 7319779, at *5 (internal quotations and citations omitted).

  6. Stine v. Kijakazi

    Civil Action 21-5492 (E.D. Pa. May. 16, 2023)

    See, e.g., Maher v. Saul, Civ. Action No. 19-5721, 2020 WL 5876808, at *5 (E.D. Pa. Sept. 9, 2020) (limitation to “simple, routine, repetitive tasks” is not the same as more restrictive limitation to “one- and two-step tasks”), Report and Recommendation adopted, 2020 WL 5849466 (Oct. 1, 2020); Podunajec v. Saul, Civ. Action No. 19-1938, 2020 WL 7319779, at *6 (M.D. Pa. Dec. 11, 2020) (“[T]he Court finds that there is a significant difference between an RFC limitation to one and two step tasks and an RFC limitation to simple, routine tasks.”)

  7. Simon v. Kijakazi

    CIVIL 1:20-cv-02064 (M.D. Pa. Mar. 18, 2022)

    A recent case from this court is instructive. In Podunajec v. Saul, 2020 WL 7319779 (M.D. Pa. Dec. 11, 2020), Magistrate Judge Saporito found that an ALJ's failure to explain why a one- to-two-step task limitation was omitted from the RFC assessment required a remand. The ALJ in that case gave great weight to one medical opinion which opined that the claimant could “understand, retain, and follow simple job instructions (i.e. perform/follow one and two step tasks/instructions).”