Forney v. Apfel

Background

A woman who applied for Social Security disability benefits said the agency was wrong to deny her claim. An Administrative Law Judge found she could not do her old jobs but could do other work and denied benefits. A federal district court agreed the record was inadequate to support the agency’s finding and entered a judgment that sent the case back to the agency for more proceedings.

Reasoning

The central question was whether a person denied benefits can appeal a district court judgment that remands the claim to the agency. The Court explained that federal law gives appeals courts jurisdiction over “final” district court decisions, and that a remand judgment under the Social Security review statute is a final, appealable judgment. The Court rejected the Ninth Circuit’s view that a claimant who obtains a remand cannot appeal, saying the claimant here got only part of the relief she asked for and is therefore still aggrieved and may appeal. The Court reversed the Ninth Circuit and allowed the claimant’s appeal to proceed.

Real world impact

This ruling lets Social Security disability applicants ask appeals courts to review district court remand orders and seek outright reversal instead of only returning to the agency. It could lead to more appeals in some cases, though the Solicitor General argued many claimants will still prefer agency proceedings. The case was sent back for further steps consistent with the opinion.