Chen v. Comm'r of Soc. SEC.

Summary

Social Security disability insurance overpayment; pro se plaintiff abandoned challenge to the Commissioner's calculation of average current earnings under 42 U.S.C. § 424a(a) by failing to raise it on appeal. The Second Circuit affirmed substantial evidence supporting the overpayment amount, holding that POMS guideline § 52150.00 merely reiterated existing regulations and that the Commissioner's later June 2016 notice reflected a remaining recoupment balance, not a revised determination. The court declined to consider new W-2 evidence offered for the first time on appeal, finding no extraordinary circumstances.