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.
