Matthew Ryan Byers v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania affirmed the Commissioner of Social Security’s denial of Matthew Ryan Byers’s claims for disability insurance benefits and supplemental security income. The court held that evidence submitted to the Appeals Council after the administrative law judge’s decision could not be used to challenge the decision’s substantial-evidence basis. The court also denied a sentence-six remand under 42 U.S.C. § 405(g) because Byers failed to establish good cause for not obtaining and presenting the neuropsychological examination before the administrative hearing.

Holdings

1. When the Appeals Council denies review, the ALJ's decision is the Commissioner's final decision, and the district court lacks authority to review the Appeals Council's decision to deny review.
2. Evidence submitted after the ALJ's decision cannot be used to argue that the ALJ's decision was not supported by substantial evidence.
3. Byers was not entitled to a sentence-six remand because he failed to establish good cause for not obtaining and presenting the neuropsychological examination before the ALJ's hearing and decision.

Questions Presented

1. Whether the court could remand because the Appeals Council allegedly failed to consider new and material evidence submitted after the ALJ's decision.
2. Whether the post-decision neuropsychological report satisfied the good-cause requirement for a sentence-six remand under 42 U.S.C. § 405(g).
3. Whether the ALJ's decision could be challenged as unsupported by substantial evidence based on evidence that was not before the ALJ.

Disposition

affirmed