Changeflow GovPing Courts & Legal Sarah H. v. Frank Bigano, Commissioner of Socia...
Priority review Enforcement Amended Final

Sarah H. v. Frank Bigano, Commissioner of Social Security - Sentence Four Remand

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Summary

The United States District Court for the Southern District of Illinois granted the parties' Agreed Motion to Remand in the Social Security disability case of Sarah H. v. Frank Bigano, reversing and remanding the Commissioner's final decision pursuant to sentence four of 42 U.S.C. § 405(g). Upon remand, the Administrative Law Judge will reconsider the evidence, offer the plaintiff an opportunity for a hearing, and issue a new decision. Judgment was entered in favor of Plaintiff on April 8, 2026.

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GovPing monitors US District Court SDIL Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 2 changes logged to date.

What changed

The court granted the parties' agreed motion and issued a sentence four remand order reversing the Commissioner's decision in Sarah H.'s Social Security disability case. Sentence four remands require a finding of error and result in judgment being entered in favor of the plaintiff. The case is remanded to the Commissioner for rehearing and reconsideration of the evidence, with the plaintiff to be offered a new hearing opportunity. Affected parties in Social Security disability proceedings should note that sentence four remands are themselves final, appealable orders that reset the administrative proceedings.

For SSA disability claimants and their representatives, this order underscores that agreed remands between the parties and the court can result in full reversal and a new hearing before an ALJ. The practical implication is that the plaintiff's disability claim will receive fresh administrative review, potentially leading to a different outcome on the merits.

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Apr 24, 2026

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April 8, 2026 Get Citation Alerts Download PDF Add Note

SARAH H. v. FRANK BIGANO, COMMISSIONER of SOCIAL SECURITY

District Court, S.D. Illinois

Trial Court Document

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS

SARAH H., )
)
Plaintiff, )
)
vs. ) CIVIL NO. 3:25-cv-01964-GCS
)
FRANK BIGANO, )
COMMISSIONER of SOCIAL SECURITY, )
)
Defendant. )

MEMORANDUM & ORDER

SISON, Magistrate Judge:

Before the Court is the parties’ Agreed Motion to Remand to the Commissioner.
(Doc. 19). The parties ask that this case be remanded for further proceedings pursuant to
sentence four of 42 U.S.C. § 405 (g). A sentence four remand (as opposed to a sentence six
remand) depends upon a finding of error, and is itself a final, appealable order. See
Melkonyan v. Sullivan, 501 U.S. 89, 98 (1991); Perlman v. Swiss Bank Corp. Comprehensive
Disability Protection Plan, 195 F.3d 975, 978 (7th Cir. 1999). Upon a sentence four remand,
judgment should be entered in favor of plaintiff. See Shalala v. Schaefer, 509 U.S. 292, 302-
303 (1993).
The parties agree that, upon remand, the ALJ will “consider the evidence, offer
plaintiff the opportunity for a hearing, and issue a new decision.”
For good cause shown, the parties’ Agreed Motion to Remand to the
Commissioner (Doc. 19) is GRANTED. The final decision of the Commissioner of Social
Security is REVERSED and REMANDED to the Commissioner for rehearing and
reconsideration of the evidence, pursuant to sentence four of 42 U.S.C. § 405 (g). The Clerk
of Court is directed to enter judgment in favor of Plaintiff.
IT IS SO ORDERED.
DATED: April 8, 2026.
Digitally signed by
. Judge Sison
SAlet D3 Date: 2026.04.08
13:51:01 -05'00"
GILBERT C. SISON
United States Magistrate Judge

Page 2 of 2

Named provisions

Sentence Four Remand

Citations

42 U.S.C. § 405(g) authority for sentence four remand
Melkonyan v. Sullivan, 501 U.S. 89, 98 sentence four remand final and appealable
Shalala v. Schaefer, 509 U.S. 292 judgment entered in favor of plaintiff on sentence four remand

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Last updated

Classification

Agency
SDIL
Filed
April 8th, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
CIVIL NO. 3:25-cv-01964-GCS
Docket
3:25-cv-01964

Who this affects

Applies to
Patients Government agencies
Industry sector
6211 Healthcare Providers
Activity scope
Social Security disability claims Administrative law judge proceedings Federal court review
Geographic scope
United States US

Taxonomy

Primary area
Healthcare
Operational domain
Legal
Topics
Public Health Judicial Administration

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