govinfo:USCOURTS-ohsd-1_26-cv-00001-0

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF OHIO 
WESTERN DIVISION 
 
ALONDA T., 
 
Plaintiff, 
 
v. 
 
COMMISSIONER OF 
SOCIAL SECURITY, 
 
Defendant. 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
JUDGE DOUGLAS R. COLE 
Magistrate Judge Vascura 
 
 
 
ORDER 
This cause comes before the Court on the joint motion of the parties to reverse 
the Commissioner’s decision and remand the matter to the Commissioner for further 
administrative proceedings pu rsuant to Sentence Four of Section 205 of the Social 
Security Act, 42 U.S.C. § 405(g) (“Sentence Four”). (See Doc. 8). For good cause shown, 
the Court GRANTS the parties’ Joint Motion, REVERSES the Commissioner’s 
decision, and REMANDS the matter, pursuant to Sentence Four. Upon remand, the 
Appeals Council will vacate the Administ rative Law Judge’s decision, take any 
further action necessary to complete the administrative record, hold a hearing, and 
issue a new decision.1 
 
1 In Follen v. Commissioner of Social Security, the Sixth Circuit recently held that in granting 
a remand under Sentence Four of Section 205, the court must “identify[] a merits defect in 
the ALJ’s analysis” and “explain its reasoning in reference to the statute, the ALJ’s decision, 
and any evidentiary defects it might see in the record.” 167 F.4th 352, 358 (6th Cir. 2026). 
The Court concludes, however, that, in the context here, Follen does not require any 
explanation beyond that set forth above. In Follen itself, unlike here, the claimant asserted 
an immediate right to benefits. Id. at 355. That is, the claimant agreed to a remand there 
only for the limited purpose of awarding benefi ts (which was different from the purpose for 
which defendant sought remand). Id. Under Follen, when the court rejects such a request, 
Case: 1:26-cv-00001-DRC-CMV Doc #: 9 Filed: 05/27/26 Page: 1 of 2 PAGEID #: <pageID>
The Court DIRECTS the Clerk to enter judgment and to TERMINATE this 
case on its docket.
SO ORDERED. 
May 27, 2026
DATE DOUGLAS R. COLE
 UNITED STATES DISTRICT JUDGE
and instead elects to remand on Sentence Fo ur grounds for further proceedings, the court 
must explain in some detail why the claimant is not immediately entitled to benefits. Id. at 
358. But where both parties agree, like here, that an error occurred, the court can simply 
reverse the judgment and allow the Commissioner another crack at the matter without 
specifying what that defect is beyond a general statement of the evidence the Administrative 
Law Judge should consider on remand and th e additional steps the Administrative Law 
Judge should take. 
ter judgment ana d to 
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NITED STATES
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Case: 1:26-cv-00001-DRC-CMV Doc #: 9 Filed: 05/27/26 Page: 2 of 2 PAGEID #: <pageID>

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