Forney v. Apfel
118 S. Ct. 1984, 524 U.S. 266, 1998 U.S. LEXIS 3886 (1998)
Rule of Law:
A district court's order remanding a Social Security disability benefit claim to the agency for further proceedings constitutes a 'final judgment' appealable under 28 U.S.C. § 1291 and 42 U.S.C. § 405(g), even when appealed by the claimant who sought outright reversal of the agency's decision.
Facts:
- Sandra K. Forney applied for Social Security disability benefits under the Social Security Act.
- A Social Security Administration Administrative Law Judge (ALJ) determined that Forney had not worked since the onset of her medical problem and was more than minimally disabled.
- The ALJ found Forney's disability prevented her from returning to her former work (cook, kitchen manager, or baker).
- The ALJ concluded that Forney's disability was not severe enough to prevent her from holding other jobs available in the economy (such as order clerk or telephone answering service operator).
- The ALJ consequently denied Forney's disability claim.
- The Administration’s Appeals Council subsequently denied Forney’s request for review of the ALJ's decision.
Procedural Posture:
- Sandra K. Forney applied for Social Security disability benefits.
- A Social Security Administration Administrative Law Judge (ALJ) denied Forney's disability claim.
- The Administration’s Appeals Council denied Forney’s request for review of the ALJ's decision.
- Forney sought judicial review of the agency's final determination in Federal District Court (District of Oregon).
- The District Court found the agency’s determination inadequately supported and entered a judgment remanding the case to the agency for further proceedings pursuant to sentence four of 42 U.S.C. § 405(g).
- Forney, seeking outright reversal of the agency's denial, sought to appeal the District Court's remand order to the Court of Appeals for the Ninth Circuit.
- The Ninth Circuit Court of Appeals did not hear Forney's claim, deciding that she lacked the legal right to appeal the remand order.
- Forney sought certiorari from the Supreme Court to review the Ninth Circuit's decision; the Supreme Court granted certiorari and appointed an amicus to defend the Ninth Circuit's judgment.
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Issue:
Does a Social Security disability claimant, who sought outright reversal of an agency decision denying benefits, have the legal right to appeal a district court order that instead remands the case to the agency for further proceedings?
Opinions:
Majority - Justice Breyer
Yes, a Social Security disability claimant has the legal right to appeal a district court order remanding the case to the agency for further proceedings. The Court found that 28 U.S.C. § 1291 grants appellate courts jurisdiction over "final decisions" of district courts, and 42 U.S.C. § 405(g) specifically empowers district courts to enter a "judgment" affirming, modifying, or reversing an agency decision with or without remanding the cause, further stating that such a "judgment...shall be final except that it shall be subject to review." Citing Sullivan v. Finkelstein (1990) and Shalala v. Schaefer (1993), the Court reaffirmed that a district court order remanding a Social Security disability case is a final judgment for appeal purposes. The Court rejected the Ninth Circuit's reasoning that Forney could not appeal because she was a 'prevailing party,' clarifying that a party is 'aggrieved' and can appeal a decision 'granting in part and denying in part the remedy requested.' Forney's complaint sought either outright reversal or, alternatively, a remand, making the remand only 'half a loaf' from her perspective, thus entitling her to appeal the denial of her broader requested relief. The Court further noted that legislative concerns about potential burdens on appeals courts do not grant courts the power to redefine statutory classes of appealable cases.
Analysis:
This case clarifies the interpretation of 'final judgment' under 28 U.S.C. § 1291, particularly in conjunction with the Social Security Act's judicial review provision, 42 U.S.C. § 405(g). It ensures that Social Security disability claimants have an immediate right to appeal a district court's remand order if they sought more comprehensive relief (e.g., outright reversal). The decision reinforces the principle that a party is 'aggrieved' and can appeal if they receive only partial relief, preventing courts from denying appeals based on a finding of 'prevailing party' when not all requested remedies were granted. This ruling also emphasizes the judiciary's role in adhering to statutory definitions of appealability rather than reinterpreting them based on policy concerns like judicial economy.
