The Social Security Commissioner Must Prove Each Element and
therefore must prove what “substantial number of jobs” means
so that the Commissioner’s decision can be reviewed by the District Court

  The Commissioner of Social Security, by and through his administrative law judges, has no Devine insight as to what the phrase “substantial number of jobs-considering age, education or work experience or assessing a claimant’s ability to adjust to other work as required by these rules” means. 

  A “common sense” decision by the ALJ must be reviewed by the US District Court as are every other findings of fact by the ALJ.  As the ALJ has no vocational expertise, the only person who can answer the question of whether a number of jobs in the national economy would be the vocational expert.  Therefore, blocking the representative from asking the VE whether 3,174 “stuffer” in a work force of approximately 150,000,000 is a “substantial number” is error and the VE should be permitted to be answer so that the answer may be reviewed by the US District Court even if it is a “common sense” standard.

  Regulations require “full consideration to all relevant facts in accordance with the definitions and discussion under vocational considerations.”  20 C.F.R. § 1569 and “full consideration must be given to all of the relevant facts in the case in accordance with the definitions and discussions of leach factor in the appropriate sections of the regulations, which will provide insight into the adjudicative weight to be according each factor.”  Medical-Vocational Guidelines, Rule 200.00(e)(2).

  “Common Sense” dictates that 29 local jobs as “Stuffer” , 169 local jobs for “nut sorter” and the  comparable miniscule national jobs when compared to 150,000,000 jobs in the nation is not “substantial” as defined by any dictionary. 

substantialMarion Webster Dictionary:

Main Entry:  sub·stan·tial 

Pronunciation: \səb-ˈstan(t)-shəl\

Function: Adjective Date:  14th century

1 a: consisting of or relating to substance b: not imaginary or illusory : real , true c: important , essential

2: ample to satisfy and nourish : full <a substantial meal>
3 a: possessed of means : well-to-do b: considerable in quantity : significantly great <earned a substantial wage>
4: firmly constructed : sturdy <a substantial house>
5: being largely but not wholly that which is specified <a substantial lie>