Meyer v. Astrue
662 F.3d 700
| 4th Cir. | 2011Background
- Meyer sustained severe injuries from a 25-foot fall in 2004, including three fractured lumbar vertebrae requiring surgery and other injuries.
- An ALJ denied Meyer's disability claim in 2008, finding no requisite disabling impairment and that Meyer could perform light work; the decision relied on lack of physician-imposed restrictions in the record.
- Meyer submitted a new letter from treating physician Dr. Bailey (August 2008) with detailed restrictions; the Appeals Council incorporated it but denied review, making the ALJ's decision the Commissioner’s final decision.
- Meyer challenged the denial, arguing the Appeals Council failed to articulate specific findings justifying denial of review.
- The district court and then the Fourth Circuit acknowledged that the Appeals Council need not articulate its reasoning when denying review, but remanded because the record contained conflicting evidence and new treating-physician evidence that required adjudication.
- On remand, the court emphasized the need to assess the weight of the treating-physician opinion and reconcile it with other evidence; the Appeals Council did not provide such analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Appeals Council's denial of review requires express findings | Meyer | Astrue | Not required; denial stands without detailed articulation |
| Whether this case should be remanded for additional fact-finding on treating-physician evidence | Meyer | Astrue | Remand for further fact-finding required |
Key Cases Cited
- Wilkins v. Sec'y, Dep't of Health & Human Servs., 953 F.2d 96 (4th Cir. 1991) (regulatory denial of review does not require articulation of reasoning)
- Sims v. Apfel, 530 U.S. 103 (S. Ct. 2000) (finality of administrator's decision and review standards)
- DeLoatche v. Heckler, 715 F.2d 148 (4th Cir. 1983) (adequate explanation required for judicial review of agency decision)
- Martinez v. Barnhart, 444 F.3d 1201 (10th Cir. 2006) (policy favoring articulate reasoning when new evidence is denied review)
- Damato v. Sullivan, 945 F.2d 982 (7th Cir. 1992) (appeals council may deny review without articulating reasoning even with new evidence)
- Jordan v. Califano, 582 F.2d 1333 (4th Cir. 1978) (when Appeals Council makes a decision, it must articulate conclusions with respect thereto)
- Myers v. Califano, 611 F.2d 980 (4th Cir. 1980) (appeals council must articulate findings when it sua sponte grants review)
- Smith v. Chater, 99 F.3d 635 (4th Cir. 1996) (new evidence presented to ALJ and evaluation of substantial evidence)