Reported / Citable
Background
Carol G. sought judicial review of the Social Security Commissioner’s denial of her application for Title II disability insurance benefits. She alleged disability beginning December 31, 2015, based on physical impairments. The agency denied her claim initially and on reconsideration, and an administrative law judge denied benefits after a hearing at which Carol and a vocational expert testified.
After the Appeals Council denied review, Carol filed suit under 42 U.S.C. § 405(g). Her summary-judgment motion argued that the ALJ applied the wrong severity standard, substituted lay judgment, evaluated her symptom evidence inconsistently, and failed to resolve inconsistencies involving the reviewing physicians. The Commissioner did not address those arguments and instead moved to reverse and remand for further administrative proceedings. Carol did not oppose remand.
The Court’s Holding
The court granted the Commissioner’s motion and ordered a sentence-four remand under 42 U.S.C. § 405(g). Because the Commissioner had already answered and presented no new evidence, the court concluded that sentence six did not apply. The requested reversal and remand for further factfinding instead fell within sentence four, which permits a court to reverse the Commissioner’s decision and remand for a rehearing.
The court reversed the Commissioner’s determination that Carol was not disabled and remanded the matter for further administrative proceedings. It dismissed the complaint without prejudice, denied Carol’s summary-judgment motion as moot, and stated that it would enter a separate final judgment. The court did not order an immediate award of benefits or decide the merits of Carol’s asserted errors.
Key Takeaways
- The Commissioner’s benefits denial was reversed, but the claimant was not awarded benefits; the agency must conduct further proceedings.
- The remand arose under sentence four of § 405(g), requiring entry of a final judgment.
- Sentence six was inapplicable because the Commissioner had already answered and did not present new evidence.
Why It Matters
The order distinguishes a sentence-four remand, which accompanies a judgment reversing or modifying the agency’s decision, from the narrower sentence-six procedure. It also confirms that an agreed request for additional administrative factfinding may support reversal and remand without resolving each alleged defect in the ALJ’s analysis.