Unreported / Non-Citable
Background
Felicity Williams Thomas brought an action against the Commissioner of Social Security challenging an administrative decision. The Commissioner filed an unopposed motion requesting entry of judgment and remand under the fourth sentence of 42 U.S.C. § 405(g).
The court explained that § 405(g) permits sentence-four and sentence-six remands. A sentence-four remand follows a merits judgment affirming, modifying, or reversing the Commissioner’s decision, while a sentence-six remand is limited to specified circumstances and does not determine the correctness of the agency’s decision.
The Court’s Holding
The court held that a sentence-four remand was appropriate because the Commissioner requested that relief and the motion was unopposed. After finding good cause, the court granted the Commissioner’s motion.
The court reversed the case and remanded it to the Commissioner for further administrative action consistent with the unopposed motion. The order therefore constituted a sentence-four disposition involving immediate entry of judgment.
Key Takeaways
- The court granted the Commissioner’s unopposed request for a sentence-four remand under 42 U.S.C. § 405(g).
- A sentence-four remand requires a merits judgment affirming, modifying, or reversing the Commissioner’s decision.
- The case was reversed and returned to the Commissioner for further administrative action.
Why It Matters
The ruling illustrates the procedural distinction between sentence-four and sentence-six Social Security remands. Because the court reversed and remanded under sentence four, judgment was entered immediately rather than deferred until the completion of post-remand agency proceedings.