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.
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.
Background
In December 2004, Meyer fell 25 feet out of a deer stand while hunting and suffered significant injuries. He fractured three lumbar vertebrae, which required reconstructive surgery. He also fractured his left wrist and injured his left shoulder, requiring additional surgery. At the time of his fall, Meyer was 51 years old and owned and operated a rural feed store.
On December 13, 2004, Dr. Byron Bailey, an attending neurosurgeon at the Medical University of South Carolina in Charleston, performed Meyer's back surgery. On December 26, Dr. Bailey discharged Meyer from the hospital, and referred him for physical and occupational therapy. Dr. Bailey observed Meyer in clinic for post-surgical follow-up through the spring of 2005, and reviewed Meyer's post-operative progress through at least April 2006.
Following his surgery, Meyer underwent extensive physical therapy at the Rehabilitation Centers of Charleston, averaging between five and 10 visits per month until his discharge in June 2006. At that time, Dr. Bailey referred Meyer to the hospital's pain management clinic. Dr. Arthur R. Smith, an anesthesiologist, treated Meyer in clinic with various injections that provided Meyer "short-term relief" from his pain. In August 2007, however, Dr. Smith ceased the injections, acknowledging that they failed to provide Meyer with any "long-term benefit."
On July 13, 2005, Meyer filed a claim for disability insurance benefits with the Social Security Administration.
Meyer’s Appeal Process
After both his initial claim and request for reconsideration were denied, Meyer requested a hearing. The ALJ heard Meyer's claim and issued an unfavorable decision on June 5, 2008. In his opinion, the ALJ followed the federal regulations governing administrative review of Social Security Disability claims, proceeding through the customary five-step sequential analysis.
Applying the first three steps, the ALJ determined that Meyer (1) had not engaged in "substantial gainful activity" since the date of his accident, (2) had the "severe impairments" of degenerative disc disease and a history of left wrist injury, but (3) did not have an impairment "that meets or medically equals" an impairment that the federal regulations define as disabling.
As the regulations instruct, the ALJ evaluated Meyer's "residual functional capacity" before proceeding to step four. The ALJ concluded that Meyer could perform "the full range" of "light work," which involves "lifting no more than 20 pounds at a time with frequent lifting or carrying of objects weighing up to 10 pounds," and "a good deal of walking or standing, or . . . sitting most of the time with some pushing and pulling of arm or leg controls." In reaching these conclusions, the ALJ found Meyer's assertion that "he suffered from constant, unrelenting" pain not entirely "credible" because it was "inconsistent with the medical evidence of record," including Meyer's "reports to his physicians, and the treatment sought and received."