Tonya T. v. Frank Bisignano, Commissioner of Social Security

Summary

The court granted Plaintiff Tonya T.’s motion for summary judgment, denied the Commissioner of Social Security’s motion, reversed the Commissioner’s decision, and remanded the case for further proceedings. The court held that the Appeals Council erred by failing to consider new, chronologically relevant, and material medical evidence concerning Plaintiff’s pain, spinal conditions, and functional limitations.

Holdings

1. When the Appeals Council erroneously refuses to consider evidence that is new, material, and chronologically relevant, it commits legal error and remand is appropriate.
2. An RFC assessment completed after the ALJ's decision is chronologically relevant when the assessment specifically states that the described symptoms and limitations applied beginning before the ALJ's decision.
3. Additional evidence is material when there is a reasonable possibility that it would change the administrative result, including by altering the claimant's RFC or the available-work determination.

Questions Presented

1. Whether the Appeals Council erred by refusing to consider new evidence submitted after the ALJ's decision.
2. Whether the evidence was chronologically relevant to the period adjudicated by the ALJ.
3. Whether the evidence was material because there was a reasonable possibility it could change the administrative result.
4. Whether remand under sentence four of 42 U.S.C. § 405(g) was appropriate.

Disposition

reversed_and_remanded