Wilson v. Heckler

609 F. Supp. 120, 1985 U.S. Dist. LEXIS 20557, 10 Soc. Serv. Rev. 495
CourtDistrict Court, W.D. Missouri
DecidedApril 19, 1985
DocketNo. 85-0046-CV-W-3
StatusPublished

This text of 609 F. Supp. 120 (Wilson v. Heckler) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilson v. Heckler, 609 F. Supp. 120, 1985 U.S. Dist. LEXIS 20557, 10 Soc. Serv. Rev. 495 (W.D. Mo. 1985).

Opinion

OPINION AND ORDER

ELMO B. HUNTER, Senior District Judge.

Before the Court is defendant’s motion for consolidation of this case with case number 82-040l-CV-W-8. The case before this Division is an appeal from the final decision of the Secretary after a remand in case number 82-0401-CV-W-8. The Secretary has filed a supplemental transcript in the earlier case and seeks to stop the independent processing of this case. Plaintiff opposes the motion solely on the ground that the complaint is concerned with a new final decision which is not dependent on any previous decision.

It is the position of the Secretary that her suggested procedure of reopening the previous appeal is required by 42 U.S.C. § 405(g) which in pertinent part provides:

[T]he Secretary shall, after the case is remanded, and after hearing such additional evidence if so ordered, modify or affirm his findings of fact on his decision, or both, and shall file with the court any such additional and modified findings of fact and decision, and a transcript of the additional record and testimony upon which his action in modifying or affirming was based. Such additional or modified findings of fact and decision shall be reviewable only to the extent provided for review of the original findings of fact and decision.

The Secretary takes this language to require her, in any remanded case, to file a supplemental transcript and obtain judicial review of her post-remand decision. See Brown v. Secretary of Health and Human Services, 747 F.2d 878, 884 (3rd Cir.1984). In effect, the Secretary reads the statute as providing that every remand to her agency made by the district court is analogous to a court of appeals’ “limited remand” wherein jurisdiction is retained for [121]*121appellate action after remand. See 16 Wright, Miller Cooper, & Gressman, Federal Practice and Procedure § 3937 (1977). In cases involving that procedure, however, jurisdiction is retained in contemplation' of post-remand appellate action on issues arising before remand. See, e.g., Citizens State Bank of Marshfield v. F.D.I.C., 718 F.2d 1440 (8th Cir.1983) (remand for agency’s clarification of the reasons for its decision-jurisdiction retained to review order after remand proceedings), Webb v. Arresting Officers, 749 F.2d 500 (8th Cir.1984) (remand for further findings before application of standard of review). In other words, appellate action on the case is postponed pending resolution of an issue necessary or helpful to the proposed appellate action.

When read in context, and with an historical perspective, the statutory language relied on by the Secretary and quoted above does not appear to apply to remands generally, but rather to a particular type of remand. The language originally appeared in the following sentence:

The court shall, on motion of the Board made before it files its answer, remand the case to the Board for further action by the Board, and may, at any time, on good cause shown, order additional evidence to be taken before the Board, and the Board shall, after the case is remanded, and after hearing such additional evidence if so ordered, modify or affirm its findings of fact or its decision, or both, and shall file with the court any such additional and modified findings of fact and decision, and a transcript of the additional record and testimony upon which its action in modifying or affirming was based.

Social Security Act Amendments of 1939, ch. 666, 53 Stat. 1360 at 1371.

Under that sentence, the agency had the power, before it filed its answer, to require the court to remand the case. Additionally, the court could, in its discretion upon a finding of good cause, send the case back to the agency for further proceedings before even deciding the issues on appeal. Congress became concerned about the availability of a remand without a decision:

Some critics have suggested that such absolute discretion gives the Secretary potential authority to remand cases back so that they can be strengthened to sustain court scrutiny. Others have suggested that such a device also may have the tendency to lead to laxity in appeals council review in that it will give the council another look at the case if the claimant decides to go to court.
Similarly, under existing law the Court itself, on its own motion or on motion of the claimant, has discretionary authority “for good cause” to remand the case back to the AU. It would appear that, although many of these court remands are justified, some remands are undertaken because the judge disagrees with the outcome of the case even though he would have to sustain it under the “substantial evidence rule.”

S.Rep. No. 96-408, 96th Cong., 2nd Sess. 58 (1979), reprinted in 1980 U.S.Code Cong. & Ad.News 1277, 1336.

The first part of the sentence, describing when a case may be remanded, was amended in 1980 to its present form to limit the reasons a case may be remanded.1

The effect and intent of the second part of the sentence was fairly clear before the [122]*122amendment.' If the agency called for a remand before it answered, or if the judge needed additional information in order to decide the case, the case would be remanded and the agency would file the results of the remand proceedings with the court for its decision. In the language relied upon by the Secretary, the phrase “after the case is remanded” referred to the earlier part of the sentence giving the Secretary the right to obtain a remand. The phrase “and after hearing additional evidence if so ordered” referred to the earlier part of the sentence giving the judge discretion to “at any time ... order • additional evidence to be taken before the Board____”

If there was any question that the grant of power to “order additional evidence” at any time did not refer to post-decision remands, it was removed by the 1980 amendment. Under that amendment, the grant of authority was limited to cases wherein there would be a showing that “there is new evidence which is material and that there is good cause for the failure to incorporate such evidence into the record in a prior proceeding.” 42 U.S.C. 405(g). The House Committee on Ways and Means, through which the amendment passed made it clear that they did not perceive the sentence to apply to eases remanded after the Secretary’s decision had been reversed. In discussing the limitation on when a Court may remand the case, the committee reported:

(O)nly 249 of these [1,257 reversals] were reversed directly by the court while 1,008 were reversed after being remanded to the appeals council. Undoubtedly, many of these court remands are justified because of the insufficiencies of the prior proceedings.

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Bluebook (online)
609 F. Supp. 120, 1985 U.S. Dist. LEXIS 20557, 10 Soc. Serv. Rev. 495, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-heckler-mowd-1985.