George S. C. v. Saul
- Robert Illman
- 1:20-cv-06218
- U.S. District Court · Northern District of California
- 6
In George S. C. v. Saul, Judge Illman ordered further review of a disability claim after a later benefits award could not be reconciled with an earlier denial.
George S. C.’s 2016 application for disability insurance benefits and the related administrative proceedings before the Commissioner of Social Security.
What happened
George S. C. sought review of a 2019 decision denying his application for disability insurance benefits. The decision found that his medically determinable impairments were not severe before his insured status ended. The agency later awarded benefits on a second application, with an onset date of September 2016.
George S. C. argued that the later award was new and important evidence proving that the earlier denial was wrong and that the court should order immediate payment for the earlier application. Andrew Saul agreed that the case should be sent back for review but argued that more administrative proceedings were needed because the records, dates, and reasons for the later award were unclear.
The court granted George S. C.’s motion in part and denied it in part, and granted Saul’s motion for remand for further proceedings. Judge Illman ruled that the court could not determine whether the two decisions were consistent or whether the later award would change the earlier outcome, so it did not order immediate payment. The court retained jurisdiction and required the parties to file periodic joint status reports.
The detailed version
- George S. C. v. Saul · No. 1:20-cv-06218
- Robert Illman
- Feb. 14, 2022
Background
George S. C. applied in 2016 for disability insurance benefits under Title II of the Social Security Act, alleging disability beginning December 31, 2012. An administrative law judge denied the application on May 16, 2019, finding that George S. C. had not engaged in substantial gainful activity but had no severe impairment through the date he last met the Act’s insured-status requirements. The Appeals Council affirmed that decision on July 9, 2020, and George S. C. sought judicial review.
During 2020, George S. C. filed a second application for disability insurance benefits. The agency issued a notice of award on October 6, 2020, granting that application with an onset date of September 2016. The opinion states that the record before the court might not include the evidence underlying the later award.
Motions and Legal Standard
Both parties sought a remand under sentence six of 42 U.S.C. § 405(g). A sentence-six remand allows a court to send a case back to the Commissioner for consideration of additional evidence when the evidence is new, material, and could not previously have been included for good cause. The parties agreed that the later notice of award was new and material and that good cause existed because it postdated the administrative decision. The dispute was whether the court should order further proceedings or direct immediate calculation and payment of benefits for the 2016 application.
Court’s Analysis
The court held that it could not determine from the available record whether the 2019 denial and the 2020 award could be reconciled. The applications involved different alleged onset dates and different dates concerning insured status. The court also could not determine what evidence supported the later award or whether that evidence would change the outcome of the earlier application.
The court rejected the request for immediate payment because the record was not shown to be complete and did not establish that further administrative proceedings would serve no useful purpose. It also explained that a later award of benefits does not automatically require a remand. Here, however, the decisions were relatively close in time and were not easily reconcilable on the record before the court, making further factual proceedings appropriate.
Disposition
The court granted in part and denied in part George S. C.’s motion for summary judgment and granted Andrew Saul’s motion for remand for further proceedings. The case was remanded concerning the 2016 application. The court retained jurisdiction during the sentence-six remand and ordered the Commissioner to return to the court after the administrative proceedings so that any necessary proceedings could be completed and a final judgment or dismissal could be entered. The parties were ordered to file joint status reports beginning August 15, 2022, and every 180 days afterward until further order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.