Eleventh Circuit Clarifies Appellate Abandonment in Social Security Appeals and Limits SSR 11-1p to Appeals Council “Not Chronologically Relevant” Findings

I. Introduction

In Belinda Belajonas v. Commissioner of Social Security (11th Cir. Feb. 5, 2026) (per curiam) (unpublished), the Eleventh Circuit affirmed the denial of Disability Insurance Benefits (DIBs) and Supplemental Security Income (SSI) after concluding that the claimant’s appellate presentation did not properly challenge the only issues the court could review.

Parties. Belinda Belajonas (claimant/appellant) sought review of the Commissioner’s denial of benefits (appellee).

Procedural posture and key issues. After an ALJ denied benefits, Belajonas submitted additional medical records to the Appeals Council. The Appeals Council denied review, stating the new submissions did “not show a reasonable probability that it would change the outcome.” In federal court, Belajonas attacked the district court’s reasoning regarding the new evidence and SSR 11-1p; on appeal, the Eleventh Circuit held she abandoned reviewable arguments by failing to contest (1) substantial evidence/correct legal standards for the ALJ decision and (2) the merits of the Appeals Council’s materiality determination. The court also clarified SSR 11-1p’s trigger: it applies only when the Appeals Council deems the evidence not chronologically relevant.

II. Summary of the Opinion

The court affirmed because Belajonas’s briefing did not challenge whether the Commissioner’s final decision was supported by substantial evidence or applied the correct legal standards. Instead, she argued the district court used inconsistent reasoning about whether the newly submitted records were chronologically relevant and whether SSR 11-1p applied.

The Eleventh Circuit held that it does not review alleged errors in the district court’s reasoning when evaluating the Commissioner’s decision, and that Belajonas abandoned any challenge to the Appeals Council’s only dispositive finding—that the additional records were not material.

Finally, the court rejected the SSR 11-1p argument on the merits of its applicability: SSR 11-1p is implicated only where the Appeals Council determines the proffered evidence does not relate to the period on or before the ALJ’s decision (i.e., is not chronologically relevant). Here, the Appeals Council denied review on materiality grounds, not chronological relevance.

III. Analysis

A. Precedents Cited

  • Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011)
    Cited for the basic scope of review in Social Security appeals: the court examines whether the Commissioner’s decision is supported by substantial evidence and whether correct legal standards were applied. In Belajonas, this frame underscored that the claimant’s brief must grapple with these reviewable questions—not merely critique the district court’s reasoning.
  • Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001)
    Establishes that when the ALJ denies benefits and the Appeals Council denies review, the ALJ’s decision becomes the Commissioner’s final decision. This mattered because Belajonas’s focus on district-court rationale did not substitute for a direct challenge to the final agency decision.
  • Ingram v. Comm'r of Soc. Sec. Admin., 496 F.3d 1253 (11th Cir. 2007)
    Addresses the framework for new evidence submitted to the Appeals Council and the reviewing court’s task when the Appeals Council considers new evidence but denies review: the question is whether the new evidence renders the denial of benefits erroneous. In Belajonas, that translated into a need to attack the Appeals Council’s stated basis (lack of materiality).
  • Washington v. Soc. Sec. Admin., Comm'r, 806 F.3d 1317 (11th Cir. 2015) (per curiam)
    Cited for two points: (1) whether evidence is new, material, and chronologically relevant is a legal question reviewed de novo; and (2) the operative standard for materiality as discussed in later Eleventh Circuit cases. The citation reinforced that even under de novo review, the appellant must actually present a developed argument directed to the Appeals Council’s legal determinations.
  • Hargress v. Soc. Sec. Admin., Comm'r, 888 F.3d 1302 (11th Cir. 2018)
    Used to summarize the claimant’s ability to present evidence at each administrative stage and to define “material” and “chronologically relevant.” Belajonas relies on Hargress to distinguish between evidence that relates to the relevant period versus evidence that might affect the outcome.
  • Sullivan v. Zebley, 493 U.S. 521 (1990)
    Cited for the proposition that Social Security Rulings are binding on all components of the Social Security Administration. The court invoked this to frame SSR 11-1p’s operational effect, while still holding it did not apply on these facts.
  • Henry v. Comm'r of Soc. Sec., 802 F.3d 1264 (11th Cir. 2015) (per curiam)
    Stands for the principle that on appeal the Eleventh Circuit reviews the Commissioner’s decision, not alleged errors in the district court’s order. This was pivotal: even if the district court’s discussion of chronological relevance was internally “tense,” that did not itself warrant reversal.
  • Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014)
    Provides the abandonment/waiver doctrine for appellate briefing: claims are abandoned when not plainly and prominently argued with supporting authority. The court applied Sapuppo to hold Belajonas abandoned (a) any challenge to the Appeals Council’s materiality finding and (b) any meaningful substantial-evidence challenge to the ALJ decision.

B. Legal Reasoning

  1. The court identified the proper objects of review.
    Under Winschel and Doughty, the Eleventh Circuit’s role is to review the Commissioner’s final decision (the ALJ’s decision where the Appeals Council denies review), for substantial evidence and correct legal standards.
  2. It narrowed the dispute to what the Appeals Council actually decided.
    The Appeals Council denied review because the additional evidence did not show a “reasonable probability” of changing the outcome—i.e., it was not material under 20 C.F.R. § 404.970(a)(5) as framed in Hargress. Under Ingram, when new evidence is submitted and review denied, the claimant must show the new evidence makes the denial erroneous.
  3. It rejected district-court-focused error as an appellate target.
    Belajonas argued that the district court’s order contained inconsistent reasoning about chronological relevance and SSR 11-1p. The Eleventh Circuit, invoking Henry, held that any district court error is not itself the basis for reversal; the appellate court reviews the agency decision.
  4. It enforced appellate briefing requirements (abandonment).
    Because Belajonas did not substantively challenge the Appeals Council’s finding that the evidence was not material—“the only issue we may review” in the posture she presented—she abandoned the issue under Sapuppo. Likewise, her only passing reference to substantial evidence, without developed argument, waived that challenge.
  5. It cabined SSR 11-1p to its triggering predicate.
    The court read SSR 11-1p as applying “only when the Appeals Council determines that newly submitted evidence is not chronologically relevant.” Because the Appeals Council denied review on materiality grounds, SSR 11-1p did not provide a path to treat the request-for-review date as a new application date in this case.

C. Impact

  • Appellate strategy in Social Security cases. The decision is a cautionary precedent (even if unpublished) that Social Security appellants must directly and fully brief: (1) substantial evidence/correct legal standards as to the ALJ decision, and/or (2) the Appeals Council’s precise basis for rejecting new evidence (e.g., materiality). Attacking the district court’s reasoning alone risks outright affirmance on abandonment grounds.
  • SSR 11-1p’s practical limits. The opinion narrows SSR 11-1p arguments by emphasizing the ruling’s predicate finding: unless the Appeals Council declares evidence not chronologically relevant, SSR 11-1p’s “return the evidence / potential new claim date” mechanism is not triggered.
  • Focus on “materiality” after Appeals Council denial. Where the Appeals Council states there is no reasonable probability the evidence would change the outcome, future litigants should expect courts to treat “materiality” as the decisive battleground—requiring a specific demonstration of how the new records would alter the ALJ’s dispositive findings (RFC, step findings, etc.).

IV. Complex Concepts Simplified

“Substantial evidence”
A deferential evidentiary standard: enough relevant evidence that a reasonable person could accept to support the agency’s conclusion. It is not a reweighing of the evidence.
Appeals Council “denies review”
The Appeals Council declines to revisit the ALJ decision; in that circumstance, the ALJ decision generally stands as the Commissioner’s final decision for judicial review.
“New, material, and chronologically relevant” evidence
Evidence submitted after the ALJ decision may prompt Appeals Council review if it is (1) new (not merely duplicative), (2) material (a reasonable probability/possibility it would change the outcome, as discussed via Hargress), and (3) chronologically relevant (relates to the period on or before the ALJ decision).
SSR 11-1p
A binding agency ruling addressing how the Appeals Council handles evidence that does not relate to the period before the ALJ decision. As applied here, the Eleventh Circuit treated SSR 11-1p as relevant only if the Appeals Council makes a “not chronologically relevant” determination.
“Abandonment”/“waiver” on appeal
If an appellant does not develop an argument with supporting reasoning and authority, the appellate court may treat the issue as forfeited and affirm without reaching the merits.

V. Conclusion

Belajonas reinforces two practical rules in Eleventh Circuit Social Security litigation: (1) appellants must squarely challenge the Commissioner’s final decision (and, where relevant, the Appeals Council’s stated basis for rejecting new evidence), not merely the district court’s reasoning; and (2) SSR 11-1p is not a catch-all remedy for post-decision records—its mechanism is tied to an Appeals Council finding that the evidence is not chronologically relevant. The case thus functions as a procedural roadmap: identify the agency’s actual rationale, brief it directly, and support each claim with developed argument and authority.