Background
Lynne M. Fletcher-Silvas appealed a district court order that remanded her application for Social Security disability insurance benefits for further proceedings before an administrative law judge. She argued the district court should have remanded only for a determination of benefits rather than further proceedings.
The court’s reasoning
The court applied the credit-as-true jurisprudence, which allows remand with instructions to award benefits only if the ALJ failed to provide legally sufficient reasons for rejecting evidence, there are no outstanding issues, and the record is fully developed. The court agreed with the district court that significant factual conflicts existed in the record, such as inconsistencies between the claimant’s testimony about her ability to walk and medical records showing normal gait, and between her reported anxiety and lack of such reports to doctors. Consequently, the court found further administrative proceedings were necessary. The court also affirmed the district court’s conclusion regarding the date last insured, noting the claimant did not file within twelve months of her prior disability period ending.
What it means going forward
The decision requires the administrative law judge to reopen the record and resolve factual conflicts before making a final disability determination, rather than awarding benefits immediately.