Unreported / Non-Citable
Background
Amanda E. applied for supplemental security income in February 2022, alleging disability beginning January 7, 2022. After the Commissioner denied the application initially and on reconsideration, ALJ Andrew Verne held a hearing and issued a January 18, 2024 decision finding her not disabled. The Appeals Council vacated that decision on August 8, 2024 and remanded for further consideration of her maximum residual functional capacity, whether she had past relevant work, and supplemental vocational-expert evidence about the effect of her limitations on the occupational base.
ALJ Verne held a new hearing on January 23, 2025, advising that he was not bound by previous determinations and would make new determinations based on the facts and circumstances presented. He heard testimony from Amanda E. and a vocational expert, then issued a March 10, 2025 decision again finding her not disabled. The Appeals Council denied review, making that decision the Commissioner’s final decision. Amanda E. filed her federal complaint on September 22, 2025 under 42 U.S.C. §§ 405(g) and 1383(c)(3), and the parties fully briefed the merits.
The Court’s Holding
The court first held that it lacked authority to review whether the March 2025 decision complied with the Appeals Council’s earlier remand instructions because the Appeals Council subsequently denied review and found no basis for changing the ALJ’s decision. It relied on Tyler v. Astrue and district-court decisions following Tyler. The court also stated in a footnote that Valentine v. Commissioner did not support Amanda E.’s claimed rule about remand instructions and contained neither the asserted discussion nor the quotation attributed to it.
The court next rejected the argument that the revised RFC violated law of the case or required preclusive effect under Chavez v. Brown. Unlike the prior determination in Chavez, the earlier ALJ decision here was not final and had been vacated by the Appeals Council. The court found no basis for giving preclusive effect to that order and no authority supporting application of law of the case to a vacated ALJ decision. A footnote also explained that Stubbs-Danielson v. Astrue did not establish the rule Amanda E. advanced on reply concerning materially different RFC findings.
Finally, the court treated the step-five challenge as relating to the RFC determination rather than accepting its procedural label. The ALJ had limited Amanda E. to light work with restrictions including occasional pushing or pulling with the right upper extremity and frequent overhead reaching, handling, or fingering. The court reviewed the ALJ’s discussion of spinal imaging, right-hand clumsiness, decreased sensation and weakness, contrary examination findings, and reported improvement after treatment. It concluded that the ALJ explained the RFC’s basis and that Amanda E.’s generalized incompatibility argument did not establish legal error or a lack of substantial evidence. The court therefore affirmed and directed judgment for the Commissioner.
Key Takeaways
- A district court applying Tyler may decline to review an ALJ’s compliance with Appeals Council remand instructions after the Appeals Council denies review of the later decision.
- A vacated, nonfinal ALJ decision does not receive the preclusive effect recognized in Chavez for prior final administrative findings.
- The court evaluated the substance of the claimant’s step-five argument as relating to the supporting RFC determination rather than accepting its procedural label.
- Detailed discussion of both limiting evidence and contrary examination findings supported the ALJ’s explanation of the right-upper-extremity restrictions.
- The judgment affirmed the denial of benefits; the order did not remand for further administrative proceedings or award benefits.
Why It Matters
The decision applies deferential Social Security review to a record containing evidence both supporting and detracting from the Commissioner’s conclusion. It emphasizes that an ALJ must explain the RFC, but a generalized assertion that medical findings are incompatible with the assessment does not itself establish reversible error. The court’s analysis also distinguishes review of the final decision’s evidentiary support from review of the agency’s internal compliance with an earlier remand order.
The ruling is case-specific and does not announce that every changed RFC is permissible. Its preclusion analysis turns on the fact that the earlier decision had been vacated and never became final, while its substantial-evidence conclusion rests on the particular medical findings and explanations in this administrative record.