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172737P.pdf   08/01/2018  John Higgins  v.  Commissioner, Social Security
   U.S. Court of Appeals Case No:  17-2737
   U.S. District Court for the Eastern District of Missouri - St. Louis   
[PUBLISHED] [Smith, Author, with Wollman and Loken, Circuit Judges] Civil case - Social Security. ALJs may properly rely on Vocational Expert testimony that a certain needed modification is part of the functional workplace, and it makes no difference that a particular workplace modification, in claimant's case, a bariatric chair, might be called an accommodation or a reasonable accommodation; what matters is that the particular modification has become prevalent and is commonly offered - whether required by the ADA or not; here, the Vocational Expert presented evidence that providing such a chair is a common accommodation, and the ALJ could rely on that evidence in finding jobs existed in the national economy that claimant could adjust to and perform.