Summary
The United States District Court for the Southern District of Illinois granted the Commissioner of Social Security’s motion for a sentence-four remand under 42 U.S.C. § 405(g). The court reversed the denial of Valorie Ann Childers-Bleier’s Disability Insurance Benefits and Supplemental Security Income claims, directing the Appeals Council to issue a favorable decision with an onset date of February 3, 2021 and to remand the earlier Disability Insurance Benefits period to an administrative law judge for further proceedings. The court directed the Clerk to enter judgment for the plaintiff and close the case.
Topics
Practice areas
Questions Presented
- Whether the court should grant the Commissioner's motion for a sentence-four remand under 42 U.S.C. § 405(g).
- What relief and administrative proceedings were required on remand for Plaintiff's DIB and SSI claims.
Holdings
- A sentence-four remand under 42 U.S.C. § 405(g) was warranted, and the Commissioner's final decision denying Plaintiff's DIB and SSI applications was reversed and remanded.
- Upon a sentence-four remand, judgment should be entered in favor of the plaintiff.
Key quotations
“A sentence four remand (as opposed to a sentence six remand) depends upon a finding of error, and is itself a final, appealable order.”
“Upon a sentence four remand, judgment should be entered in favor of the plaintiff.”
Factual background
Plaintiff filed concurrent DIB and SSI claims on August 27, 2021. The parties agreed that, on remand, the Appeals Council would find Plaintiff disabled as of February 3, 2021, while the period from June 10, 2020 through February 2, 2021 remained unadjudicated or unfavorable. The parties further agreed that the remaining DIB period should be remanded to an ALJ for evaluation of the medical opinions, residual functional capacity findings, and any necessary additional vocational evidence.
Procedural history
Plaintiff applied for concurrent Disability Insurance Benefits and Supplemental Security Income claims. An administrative law judge issued an unfavorable decision on July 3, 2023; the Appeals Council remanded on November 9, 2023; and the ALJ again found Plaintiff not disabled on July 25, 2024. In the district court, the Commissioner moved for a sentence-four remand, which the court granted, reversing the Commissioner's final decision and remanding with specified instructions.
Remand instructions
The Appeals Council must issue a favorable decision on Plaintiff's DIB and SSI claims with an onset date of February 3, 2021, and remand Plaintiff's Title II DIB claim for June 10, 2020 through February 2, 2021 to an ALJ. The ALJ must evaluate the DIB claim for that unfavorable period, including the medical opinions and RFC findings; obtain additional vocational expert testimony if warranted; take any further action necessary to complete the administrative record; offer Plaintiff an opportunity for a hearing; and issue a new decision.