Jack Bloodsworth v. Margaret M. Heckler, Secretary of Health and Human Services

Summary

The Eleventh Circuit held that a claimant may obtain judicial review under 42 U.S.C. § 405(g) of an Appeals Council denial of an untimely request for review. On the merits, the court concluded that the Secretary's determination that Jack Bloodsworth was not disabled was unsupported by substantial evidence because the ALJ improperly rejected treating-physician opinions and evidence of disabling pain. The court reversed the denial of benefits and held that Bloodsworth met his initial burden of proving disability from his former occupation.

Holdings

1. An Appeals Council decision dismissing an untimely request for review without good cause is a final decision made after a hearing within the meaning of 42 U.S.C. § 405(g), and is subject to judicial review in federal district court.
2. The Secretary's determination that Bloodsworth was not disabled from performing his former occupation was not supported by substantial evidence.
3. Bloodsworth was not entitled to an automatic finding of disability under section 1.05(C) of Appendix I because the medical evidence did not establish the listed level of severity; vocational factors therefore had to be considered.

Questions Presented

1. Whether the federal district court had jurisdiction under 42 U.S.C. § 405(g) to review the Appeals Council's dismissal of an untimely request for review for lack of good cause.
2. Whether the Secretary's determination that Bloodsworth was not disabled from performing his former occupation was supported by substantial evidence.
3. Whether the evidence established disability under section 1.05(C) of Appendix I to Title 20 of the Code of Federal Regulations without consideration of vocational factors.

Disposition

reversed_and_remanded