Hugh M. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Maryland reviews the denial of Hugh M.'s claim for Supplemental Security Income. The court grants the Commissioner's motion for a sentence-four remand and denies the claimant's request for remand for payment of benefits, holding that further evaluation is warranted regarding vocational-expert evidence and compliance with SSR 24-3p at step five. The court reverses the Commissioner's decision in part, remands for further proceedings, and closes the case.

Holdings

1. Remand for further administrative proceedings was warranted because the vocational-expert evidence did not adequately comply with SSR 24-3p and the record lacked sufficient explanation to permit meaningful review of the finding that Hugh M. could perform a significant number of jobs in the national economy.
2. Remand for payment of benefits was not warranted merely because the claim had been pending for nearly ten years; an award without remand is appropriate only in the unusual case where the record clearly establishes entitlement to benefits or no substantial-evidence basis could support denial.

Questions Presented

1. Whether the ALJ’s step-five finding was adequately supported when the vocational expert did not identify the data sources used to estimate available jobs or explain applicable differences between those sources and the information used in the disability regulations.
2. Whether the court should remand for payment of benefits rather than for further administrative proceedings because the case had been pending for many years and Hugh M. argued that the record established disability.

Disposition

reversed_and_remanded