Reported / Citable
Background
Melissa Low sought judicial review under 42 U.S.C. § 405(g) after the Commissioner of Social Security denied her Title II application for disability insurance benefits. Low argued that the administrative law judge failed to account for the full limiting effects of her mental impairments in the residual-functional-capacity assessment.
After answering the complaint, the Commissioner filed an unopposed motion for reversal and remand under sentence four of § 405(g). The Commissioner requested further development of the medical record, reevaluation of Low’s symptoms and medical-opinion evidence, a new hearing, and a new decision.
The Court’s Holding
Magistrate Judge Christine L. Stetson recommended granting the Commissioner’s unopposed motion. The report concluded that a sentence-four remand was appropriate because the request was favorable to Low, unopposed, and supported by good cause.
The magistrate judge recommended reversing the Commissioner’s decision and remanding for further administrative proceedings. The recommendation called for the ALJ to further evaluate the case as identified by the Commissioner and offer Low a new de novo administrative hearing.
Key Takeaways
- This is a report and recommendation, subject to objections and review by the district judge.
- The recommended disposition is a sentence-four reversal and remand under 42 U.S.C. § 405(g).
- On remand, the agency would further develop the record and reassess symptoms and medical-opinion evidence.
Why It Matters
The recommendation would return the disability claim to the agency without resolving the merits of Low’s challenge to the prior decision. It underscores that the Commissioner may seek a sentence-four remand after answering when further administrative development is warranted.