A Social Security residual functional capacity may limit contact with supervisors, coworkers, or the public. In Kyle P. v. Bisignano, decided October 16, 2026, a Utah federal court considered whether the phrase “brief and superficial interaction” was too vague to support a denial of Disability Insurance Benefits and SSI.
The RFC separated different kinds of workplace contact
Kyle P. alleged disability from anxiety, depression, and insomnia. The ALJ found that he could occasionally interact with supervisors and could have brief and superficial interaction with coworkers and the public while remaining on task.
A vocational expert testified that this limitation ruled out Kyle P.’s past retail jobs because they required too much interaction. The expert identified other work, including laundry worker, stores laborer, and mail clerk. The ALJ relied on that testimony and denied the claim.
The hearing record supplied context
In federal court, Kyle P. argued that “brief and superficial” was undefined and that the ALJ overlooked his difficulty sustaining employment. The court disagreed. It read the ALJ’s decision as a whole and found that the ALJ had considered the work history and cited exhibits describing his symptoms and employment.
The court also found that the term had enough meaning in this case. Kyle P. had testified about helping retail customers, finding products, handling calls, attending meetings, and supervising employees. The vocational expert heard that testimony and explained that the Dictionary of Occupational Titles did not address social contact with the same specificity, so she relied on professional experience.
Counsel did not ask the expert to define the phrase at the hearing. The court found no requirement to convert “brief” into a fixed number of minutes or use only language found in the DOT. It also concluded that any error would have been harmless because the expert selected jobs using the stated limitation.
Describe social demands and test vocational terms
A useful record explains the frequency and quality of contact: responding to criticism, asking for help, working near others, coordinating tasks, serving customers, or handling conflict. It should also identify why work ended or hours changed. At a hearing, focused questions can clarify what the expert understands a social restriction to mean, which duties it excludes, and whether the answer rests on the DOT or professional experience.
This nonprecedential district-court ruling was limited to its record. The court did not approve “brief and superficial” language for every case. It affirmed the denial, with no remand and no benefits award.
Source: Kyle P. v. Bisignano, 2026 U.S. Dist. LEXIS 237459 (D. Utah Oct. 16, 2026).
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