David W. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviewed the denial of David W.'s Supplemental Security Income claim. The court held that the Appeals Council erred by refusing to consider new, material evidence from Dr. Kalpana Patel and remanded the matter for further administrative proceedings.

Holdings

1. The Appeals Council is required to review a denial when it receives evidence that is new, material, and relates to the period on or before the ALJ's decision.
2. Dr. Patel's opinion and treatment notes were new, noncumulative, material, and related to the period at issue.
3. Remand was required because the Appeals Council failed to consider qualifying new evidence and the error could have affected the disability determination.

Questions Presented

1. Whether the Appeals Council erred by refusing to consider Dr. Patel's opinion and treatment notes submitted after the ALJ's decision.
2. Whether the additional evidence was new, material, and related to the period on or before the date of the ALJ's decision.
3. Whether remand was required because the Appeals Council's failure to consider the evidence prejudiced David.

Disposition

reversed_and_remanded