Reported / Citable
Background
James W. sought judicial review of the Social Security Administration’s denial of an application for supplemental security income under Title XVI of the Social Security Act. The application alleged disability beginning October 30, 2021, based on anxiety, PTSD, heart problems, shoulder and right-foot injuries, bronchitis, and asthma.
The agency denied the claim initially and on reconsideration. After a hearing at which the plaintiff and a vocational expert testified, an administrative law judge found at step five that the plaintiff could perform jobs existing in significant numbers in the national economy. The Appeals Council denied review.
In district court, the plaintiff moved for summary judgment and argued that the ALJ had improperly evaluated the medical opinions. The Commissioner did not address that argument but moved to reverse the disability determination and remand the matter for further administrative proceedings. The plaintiff did not oppose the Commissioner’s request.
The Court’s Holding
The court granted the Commissioner’s motion and ordered a sentence-four remand under 42 U.S.C. § 405(g). It explained that sentence four permits a district court to reverse the Commissioner’s decision, with or without remanding for a rehearing, and that a request for further administrative proceedings is properly handled through that provision.
The court reversed the Commissioner’s determination that the plaintiff was not disabled and remanded the case for further proceedings. It did not award benefits or decide the merits of the plaintiff’s challenge to the ALJ’s evaluation of the medical opinions.
The court also dismissed the complaint without prejudice, denied the plaintiff’s summary-judgment motion as moot, and stated that it would enter a separate final judgment.
Key Takeaways
- The Commissioner’s disability determination was reversed, but the court did not direct an award of benefits.
- The remand was entered under sentence four of 42 U.S.C. § 405(g), requiring a final judgment.
- The plaintiff’s medical-opinion arguments were not resolved because the unopposed remand request made the summary-judgment motion moot.
Why It Matters
The order distinguishes a sentence-four remand from a sentence-six remand and confirms that a post-answer request to reverse and return a case for additional agency proceedings falls under sentence four when no new evidence is presented.
For the claimant, the ruling vacates the existing nondisability determination and returns the claim to the Social Security Administration, where further proceedings—not an immediate payment of benefits—will determine the next outcome.