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Meyer v. Astrue
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Meyer v. Astrue, 662 F.3d 700 (4th Cir. 2011), was a landmark Social Security Disability Insurance case argued in federal court, resolving a conflict within the circuit over the summary denial of requests for review when new evidence is submitted to the Appeals Council.
Meyer v. Astrue | |
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Court | United States Court of Appeals for the Fourth Circuit |
Full case name | Maurice E. Meyer, III v. Michael J. Astrue, Commissioner of the Social Security Administration |
Argued | October 27, 2011 |
Decided | December 2, 2011 |
Citation | 662 F.3d 700 |
Court membership | |
Judges sitting | Diana Gribbon Motz, Robert Bruce King, Allyson Kay Duncan |
Case opinions | |
Majority | Motz, joined by King, Duncan |
After suffering severe injuries in an accidental fall, Maurice Eugene Meyer applied for Social Security Disability insurance benefits. An administrative law judge (ALJ) denied his claim, noting that Meyer failed to provide an opinion from his treating physician. When Meyer requested review of his claim by the Appeals Council, he submitted a letter from his treating physician detailing the injuries and recommending significant restrictions on Meyer's activity. The Appeals Council made this letter part of the record but summarily denied Meyer's request for review; thus, the ALJ's decision denying benefits became the final decision of the Commissioner of the Social Security Administration. Meyer appealed, on the grounds that the Appeals Council did wrong in failing to articulate specific findings justifying its denial of his request for review. The court rejected this argument and ruled that the Appeals Council did not have to explain its reasoning when denying review of an ALJ decision, but because in this case the court could not determine if substantial evidence supported the denial of benefits, the court reversed and remanded.