Meyer, III v. Astrue, No. 10-1581 (4th Cir. 2011)
Annotate this CasePlaintiff applied for Social Security disability insurance benefits and an ALJ denied the claim, noting that plaintiff failed to provide an opinion from his treating physician. When plaintiff 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 plaintiff's activity. The Appeals Council made this letter part of the record but denied plaintiff's request for review. Thus, the ALJ's decision denying benefits became the final decision of the Commissioner of the Social Security Administration. Plaintiff appealed, contending that the Appeals Council erred by failing to articulate specific findings justifying its denial of his request for review. The court rejected the argument and held that the Appeals Council need not 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.
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