Unreported / Non-Citable
Background
M.E.A., representing himself, sought disability insurance benefits based principally on recurring migraine headaches. An administrative law judge concluded that the impairments were not disabling and denied benefits. M.E.A. asked the district court to reverse, challenging the treatment of his symptoms and the evidence used to determine his ability to work.
The Commissioner defended the decision as supported by substantial evidence. M.E.A. also submitted later medical material and sought a separate remand under sentence six of 42 U.S.C. section 405(g), which permits consideration of genuinely new and material evidence when good cause explains why it was not presented earlier.
The Court’s Holding
The court reversed and remanded for further administrative proceedings, concluding that the existing disability determination could not stand without a proper reassessment of the record and M.E.A.’s functional limitations. The remand was open-ended rather than restricted to a single issue, leaving the agency to revisit the necessary steps of the disability analysis.
The court separately rejected sentence-six relief for the later medical submissions. M.E.A. did not adequately show that the new material changed the significance of the earlier treatment or imaging, and he did not establish good cause for failing to present it during the agency proceedings. Obtaining a more favorable report after a denial is not, by itself, enough.
Key Takeaways
- Migraine claims require analysis of frequency, duration, treatment response, and work-related effects, even when objective testing is limited.
- A remand based on errors in the existing record is distinct from a sentence-six remand based on evidence first offered in court.
- Claimants should submit favorable evidence during the agency process whenever possible and document any genuine obstacle to doing so.
- An unrestricted remand allows the agency to rebuild the analysis rather than merely correct a clerical point.
Why It Matters
Disability practitioners should develop headache evidence in functional terms: missed days, time off task, need for a dark room, medication side effects, and the consistency of symptoms across treatment records. Those details often matter more than a diagnosis standing alone.
The ruling also reinforces that district-court review is generally confined to the administrative record. Waiting until litigation to secure a supportive opinion creates an additional, demanding good-cause problem.