The U.S. Court of Appeals for the Sixth Circuit issued a published opinion Tuesday establishing that district courts must explicitly rule on Administrative Law Judge decisions before remanding Social Security disability cases back to the Social Security Administration.
In *Pamela J. Follen v. Commissioner of Social Security* (6th Cir. 2026), the appeals court vacated a district court's remand order, holding that federal courts cannot bypass their judicial review responsibilities under federal law. The decision clarifies procedural requirements that govern how district courts handle Social Security disability appeals.
The case originated when Pamela J. Follen appealed a Social Security Administration decision denying her disability benefits. The U.S. District Court for the Northern District of Ohio at Akron had remanded the case back to the SSA without making an explicit determination about whether to affirm, modify, or reverse the Administrative Law Judge's denial of benefits.
Circuit Judge John K. Bush, writing for a three-judge panel that included Circuit Judges Jane B. Stranch and Amul R. Davis, addressed the central legal question of whether such a remand procedure complies with federal statutory requirements. The court examined the language of 42 U.S.C. § 405(g), known as Sentence Four, which governs judicial review of Social Security Administration decisions.
The Sixth Circuit held that district courts cannot simply remand cases to the SSA without first fulfilling their statutory obligation to review the ALJ's decision. Under federal law, courts must explicitly state whether they are affirming, modifying, or reversing the administrative decision before ordering any remand proceedings.
This procedural requirement ensures that federal courts properly exercise their judicial review function rather than automatically sending cases back to the administrative agency. The ruling reinforces the principle that district courts must engage in meaningful review of Social Security disability determinations.
The case was argued before the Sixth Circuit on Nov. 17, 2025, and decided Feb. 11, 2026. Follen was represented by Eric S. McDaniel and Matthew J. Kasper of Malyuk McDaniel Kasper LLC in Cuyahoga Falls, Ohio. The Social Security Administration was represented by Meghan O'Callaghan and Dorrelyn K. Dietrich.
The decision carries particular significance because it was recommended for publication under Sixth Circuit Internal Operating Procedure 32.1(b), meaning it establishes binding precedent within the circuit. Published opinions from federal appeals courts serve as authoritative guidance for district courts and practitioners handling similar cases.
Social Security disability appeals follow a complex administrative and judicial process. Claimants who are denied benefits by the SSA can request reconsideration, then appeal to an Administrative Law Judge. If the ALJ denies benefits, claimants can appeal to the SSA's Appeals Council and ultimately to federal district court.
At the district court level, judges review the administrative record to determine whether the SSA's decision was supported by substantial evidence and followed proper legal standards. Courts can affirm the agency's decision, reverse it and award benefits, or remand the case for further proceedings.
The Sixth Circuit's ruling in *Follen* clarifies that the remand option cannot be used as a shortcut that bypasses the court's primary responsibility to evaluate the merits of the administrative decision. This ensures that claimants receive proper judicial review of their cases before being sent back through additional administrative proceedings.
The decision affects Social Security disability practice throughout the Sixth Circuit, which covers Kentucky, Michigan, Ohio, and Tennessee. District courts in these states must now ensure they explicitly rule on ALJ decisions before ordering any remands to the SSA.
For disability claimants, the ruling provides important procedural protections by requiring courts to engage substantively with their cases rather than automatically deferring to administrative processes. However, it may also extend the time required to resolve appeals, as courts must now make explicit determinations about ALJ decisions.
The case demonstrates the ongoing judicial oversight of Social Security Administration procedures and the importance of proper procedural compliance in federal disability appeals. As Social Security disability claims continue to represent a significant portion of federal court dockets, such precedential rulings help establish clear standards for case processing.
The *Follen* decision joins other recent Sixth Circuit precedents that emphasize the importance of thorough judicial review in Social Security cases, reflecting the circuit's commitment to ensuring that disability claimants receive fair and complete consideration of their appeals through the federal court system.