I. Introduction

This commentary examines the Eleventh Circuit’s unpublished, per curiam decision in Michael A. Minton v. Social Security Administration, Commissioner, No. 24‑13864 (11th Cir. Nov. 18, 2025), affirming the denial of Disability Insurance Benefits (DIB).

The appeal turns on a single but increasingly common question in Social Security litigation:

• Did the Social Security Administration’s Appeals Council err in refusing to grant review after receiving additional psychological evidence – specifically a narrative evaluation and a one‑page check‑box form opinion by Dr. June Nichols – submitted after the ALJ’s decision?

The Eleventh Circuit uses this case to:

• Reinforce the demanding materiality / “reasonable probability of change” standard for new evidence before the Appeals Council under 20 C.F.R. § 404.970(a)(5);
• Clarify that courts will not infer unstated “implicit findings” by the Appeals Council on newness or materiality when the Council is silent;
• Confirm that the Chenery doctrine does not bar district courts (or the Eleventh Circuit) from articulating reasons to uphold an Appeals Council denial of review, given that the Appeals Council need not supply detailed reasoning at all; and
• Continue a line of Eleventh Circuit authority treating Dr. Nichols’s brief, check‑box mental health forms as weak, often internally inconsistent, and rarely sufficient to meet the Appeals Council’s materiality threshold.

Although designated “Not for Publication” and therefore non‑precedential in the Eleventh Circuit, the opinion is an instructive synthesis of prior circuit law, and it carries significant persuasive weight in ongoing Social Security practice.

II. Factual and Procedural Background

A. The Claimant and His Alleged Impairments

Michael Minton applied for Disability Insurance Benefits on December 19, 2018, alleging disability beginning August 24, 2018. He claimed a broad range of physical and mental impairments, including:

• Cardiac issues: coronary artery disease, supraventricular arrhythmia, atrial fibrillation, chest pain, high blood pressure;
• Musculoskeletal and orthopedic issues: lumbosacral spine strain, bilateral plantar fasciitis, bilateral ankle tenosynovitis, left knee meniscal tear;
• Respiratory/ENT conditions: chronic sinusitis, sleep apnea, rhinitis, asthma/shortness of breath, tinnitus;
• Mental health conditions: post‑traumatic stress disorder (PTSD), anxiety, depression.

These conditions together formed the foundation of his claim that he could not sustain work on a regular and continuing basis under the Social Security Act.

B. The Administrative Proceedings

The Social Security Administration (SSA) initially denied the claim. Mr. Minton requested a hearing before an Administrative Law Judge (ALJ). Two hearings were held, and at the final hearing the ALJ received testimony from Mr. Minton and a vocational expert.

The ALJ then issued a “lengthy decision” denying benefits, concluding:

• Mr. Minton retained the residual functional capacity (RFC) to perform light work; and
• There existed a significant number of jobs in the national economy that he could perform.

The ALJ evaluated medical opinions and records from, among others, Drs. Victoria Hogan, Guendalina Ravello, and Samuel Fleming and found the denial appropriate for the relevant period.

C. Appeal to the Appeals Council and Submission of New Evidence

Mr. Minton sought review by the Appeals Council. The Council’s notice informed him that he could submit additional evidence. Under 20 C.F.R. § 404.970(a)(5), the Appeals Council must review a case if, among other things, it:

“receives additional evidence that is new, material, and relates to the period on or before the date of the hearing decision, and there is a reasonable probability that the additional evidence would change the outcome of the decision.”

Mr. Minton mailed multiple batches of additional medical records on:

• January 28, 2022;
• February 8, 2022;
• February 28, 2022; and
• May 12, 2022.

On appeal to the Eleventh Circuit, only two items are at issue, both authored by psychologist Dr. June Nichols:

• The “Nichols Report” – a December 7, 2021, narrative psychological evaluation including a mental status examination and a summary of Mr. Minton’s history, describing him as functioning in the “average range of intellectual ability.”
• The “Nichols Form” – a one‑page “mental health statement” dated January 13, 2022, consisting of eight yes/no questions and three fill‑in‑the‑blank items, purporting to assess Mr. Minton’s mental functional limitations back to August 24, 2018.

The Nichols materials collectively suggested that, while Mr. Minton could understand, remember, and carry out simple instructions and maintain an ordinary routine without special supervision, he had significant limitations in:

• attention and concentration;
• punctuality and persistence;
• adapting to routine changes;
• interacting appropriately with supervisors and co‑workers; and
• maintaining socially appropriate behavior.

D. The Appeals Council’s Disposition

The Appeals Council denied review. It:

• Found that the Nichols Report did not relate to the period at issue (thus, not chronologically relevant); and
• Found that the Nichols Form did not show a reasonable probability of changing the outcome of the ALJ’s decision (thus, not material under § 404.970(a)(5)).

Accordingly, the ALJ’s decision became the Commissioner’s final decision.

E. District Court Review

Mr. Minton sought judicial review in the Northern District of Alabama. Among other arguments, he asserted:

• The Nichols Form was “material” because it was relevant, probative, and created a reasonable possibility of changing the administrative outcome;
• The Appeals Council’s different treatment of the Nichols Form and Nichols Report – although they reflected “the same Nichols Opinion” – was arbitrary;
• The Nichols Report was chronologically relevant and had to be read with the Nichols Form;
• The Appeals Council could not, consistent with 20 C.F.R. § 404.970(c), rely on rationales on appeal that it had not articulated when denying review.

The district court:

• Agreed with Mr. Minton that the Appeals Council erred in finding the Nichols Report not chronologically relevant, relying on the Eleventh Circuit’s decision in Ring v. Comm’r Soc. Sec. Admin., 728 F. App’x 966 (11th Cir. 2018); but
• Nevertheless held that the Nichols materials were not material because they were internally inconsistent, insufficiently supported, and contradicted the opinions of Drs. Fleming and Ravello, which the ALJ had found persuasive.

The district court therefore concluded that, even assuming error regarding chronological relevance, any error was harmless because there was no “reasonable probability” the Nichols materials would change the ALJ’s decision.

F. Appeal to the Eleventh Circuit

On appeal, Mr. Minton advanced four principal arguments:

1. The Appeals Council’s denial of review was arbitrary and internally inconsistent because it treated the Nichols Report and Nichols Form differently despite both being part of the same “Nichols Opinion.”
2. Under the Chenery doctrine, the Eleventh Circuit (and the district court) could not affirm based on rationales not provided by the Appeals Council itself; he also suggested that the harmless‑error doctrine should not apply.
3. The Nichols materials were “material” under § 404.970(a)(5) because they established severe, work‑preclusive mental limitations and thus created at least a “reasonable probability” of a different outcome.
4. The Nichols Report was chronologically relevant to the period adjudicated by the ALJ.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit affirmed the district court’s judgment and, in effect, the Commissioner’s denial of benefits.

The court’s main holdings were:

1. No Internal Inconsistency in the Appeals Council’s Treatment of Nichols Materials.
   The Appeals Council’s decision to:
   • treat the Nichols Report as not chronologically relevant, and
   • treat the Nichols Form as not showing a reasonable probability of changing the outcome
   was not “arbitrary” or internally inconsistent. The court refused to infer that silence regarding “newness” or “materiality” implied implicit findings on those elements.
2. The Chenery Doctrine Does Not Bar Courts from Supplying Reasons for Appeals Council Denials.
   Relying on its own unpublished decision in Green v. Comm’r, Soc. Sec. Admin., 695 F. App’x 516 (11th Cir. 2017), the court held that Owens v. Heckler, 748 F.2d 1511 (11th Cir. 1984), and the Chenery doctrine apply differently to ALJ decisions than to Appeals Council denials. Because the Appeals Council is not required to give a detailed rationale when it denies review, a reviewing court may state its own reasons for concluding that the denial was proper.
3. The Nichols Opinion Was Not Material Under § 404.970(a)(5).
   The court agreed with both the Appeals Council and the district court that the Nichols Report and Nichols Form did not show a “reasonable probability” of changing the ALJ’s decision. The court emphasized:
   • internal inconsistencies within the Nichols materials;
   • conflicts with other record evidence, particularly persuasive opinions from Drs. Fleming and Ravello; and
   • lack of explanation or supporting medical rationale for the extreme limitations asserted.
   The court drew parallels to its prior unpublished decisions in Reynolds v. Soc. Sec. Admin., Comm’r, 2022 WL 853660 (11th Cir. Mar. 23, 2022), and Spurgeon v. Comm’r of Soc. Sec. Admin., 2024 WL 1395258 (11th Cir. Apr. 2, 2024), which had also rejected Dr. Nichols’s terse mental health “statements” as insufficiently material.
4. No Need to Reach Chronological Relevance.
   Because the court found the Nichols evidence not material, it explicitly declined to decide whether the Nichols Report was chronologically relevant. Even assuming it was chronologically relevant, it still would not justify Appeals Council review because it failed the materiality test.

The court therefore affirmed: “We affirm the district court’s decision. AFFIRMED.”

IV. Detailed Analysis

A. The Legal Framework for New Evidence Before the Appeals Council

Several regulatory and doctrinal principles frame the court’s analysis.

1. The Regulatory Standard – 20 C.F.R. § 404.970(a)(5)

Under the current regulation, the Appeals Council must review an ALJ’s decision when it:

“receives additional evidence that is new, material, and relates to the period on or before the date of the hearing decision, and there is a reasonable probability that the additional evidence would change the outcome of the decision.”

This incorporates four key requirements that commonly arise in litigation:

• Newness – the evidence must not have been before the ALJ and cannot be merely duplicative;
• Materiality – defined, in prior Eleventh Circuit decisions, as evidence for which a “reasonable possibility” (now, in regulatory text, “reasonable probability”) exists that it would change the administrative result;
• Chronological relevance – the evidence must relate to the period on or before the ALJ’s decision date;
• Reasonable probability of outcome change – practically, this is the heart of the “materiality” inquiry; the court’s analysis here focuses heavily on that aspect.

2. Prior Eleventh Circuit Cases Establishing the Standard

The court cites a line of Eleventh Circuit authority interpreting these requirements:

• Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253 (11th Cir. 2007) – recognizes that claimants may present evidence at each stage of the administrative process and that the Appeals Council must consider new, material, chronologically relevant evidence.
• Washington v. Soc. Sec. Admin., 806 F.3d 1317 (11th Cir. 2015) – foundational for defining chronological relevance of post‑decision evidence.
• Hargress v. Comm’r, Soc. Sec. Admin., 883 F.3d 1302 (11th Cir. 2018) – uses the “reasonable possibility” formulation for materiality and further elaborates on chronological relevance.
• Mitchell v. Comm’r of Soc. Sec. Admin., 771 F.3d 780 (11th Cir. 2014) – holds that the Appeals Council is not required to provide a detailed rationale when denying review and that cumulative evidence does not require remand.
• Pupo v. Comm’r of Soc. Sec. Admin., 17 F.4th 1054 (11th Cir. 2021) – confirms that the court of appeals reviews de novo the Appeals Council’s refusal to consider new evidence.

Minton builds on these authorities, especially the interplay between Mitchell and the later unpublished decisions, to reinforce how strictly materiality is applied.

B. Precedents Cited and Their Role in the Court’s Reasoning

1. Tieniber v. Heckler and the Rejection of Implied Findings

Mr. Minton argued that because the Appeals Council addressed only “chronological relevance” for the Nichols Report, and only “reasonable probability” for the Nichols Form, it implicitly found that:

• the Nichols Report was new and material; and
• the Nichols Form was new and chronologically relevant.

The Eleventh Circuit rejected this “implicit findings” theory by reference to Tieniber v. Heckler, 720 F.2d 1251 (11th Cir. 1983). In Tieniber, the court:

refused to infer an implicit credibility finding by an ALJ without an explicit finding or “implication … so clear as to amount to a specific credibility finding.”

Applying Tieniber, the court held that it would not infer unstated conclusions by the Appeals Council regarding “newness” or “materiality” simply because the Council discussed only certain elements. Absent a “clear implication” that the Council had made specific findings, courts must not invent implied determinations.

Consequently, the court found no internal inconsistency in the Appeals Council’s treating:

• the Nichols Report as not chronologically relevant; and
• the Nichols Form as failing the reasonable‑probability (materiality) test.

2. Chenery, Owens, and Green: The Scope of Judicial Review

Mr. Minton invoked the well‑known Chenery doctrine:

“Chenery limits judicial review of agency decisions to the grounds used by the agency in their adjudication.” (citing SEC v. Chenery Corp., 318 U.S. 80 (1943)).

He further cited Owens v. Heckler, 748 F.2d 1511 (11th Cir. 1984), arguing that a reviewing court may not supply post hoc rationalizations for an agency decision, particularly when the Appeals Council’s explanation is sparse.

The Eleventh Circuit clarified, as it had in Green v. Comm’r, Soc. Sec. Admin., 695 F. App’x 516 (11th Cir. 2017), that:

• Owens addressed a very different situation: the Appeals Council’s inability to invent “plausible reasons” for an ALJ’s decision when the ALJ failed to articulate necessary findings (e.g., for credibility or weight of the evidence);
• Owens and the Chenery rule focus on the need for ALJs – who are the primary fact‑finders – to articulate adequate reasoning;
• By contrast, the Appeals Council has no obligation to provide a “detailed explanation when it denies review,” as the court reaffirmed from Mitchell.

Thus, where an ALJ must articulate a basis for his decision, the Appeals Council need not do so when it simply denies review. This distinction allows reviewing courts to:

• examine the record (including the new evidence); and
• determine for themselves whether the regulatory criteria for Appeals Council review were met,

without being limited to the Appeals Council’s sparse rationale. The court therefore held that Owens “imposes no limit on our review of the Appeals Council’s decision denying review.”

3. Reynolds, Spurgeon, and Sryock: Evaluating Dr. Nichols’s Mental Health Opinions

The court’s analysis of the Nichols materials heavily relies on:

• Reynolds v. Soc. Sec. Admin., Comm’r, 2022 WL 853660 (11th Cir. Mar. 23, 2022) – another case involving a one‑page mental health statement from Dr. Nichols. There, the court found no reasonable probability of a changed result where the statement:
  • was unsupported by medical records,
  • was contradicted by other evidence, and
  • was inconsistent with Dr. Nichols’s own comprehensive evaluation.
• Spurgeon v. Comm’r of Soc. Sec. Admin., 2024 WL 1395258 (11th Cir. Apr. 2, 2024) – concluding that an opinion lacked materiality where it contradicted and was inconsistent with other medical records and failed to adequately explain the basis for its stated limitations.
• Sryock v. Heckler, 764 F.2d 834 (11th Cir. 1985) – reiterating that an ALJ (and by extension, the Commissioner) is “free to reject any physician’s opinion when the record as a whole supports a contrary conclusion.”

The court also cites Mitchell again for the proposition that evidence that is merely cumulative of what was already before the ALJ does not require Appeals Council review or remand.

These precedents collectively support the conclusion that:

• Check‑box or short‑form mental health statements, especially by Dr. Nichols, will rarely be deemed sufficiently material when:
  • they conflict with longer narrative evaluations,
  • are unsupported by treatment notes, or
  • are at odds with other persuasive medical opinions in the record.

C. The Court’s Legal Reasoning Applied to the Nichols Evidence

1. No “Arbitrary” Disparate Treatment of the Nichols Report and Nichols Form

Mr. Minton characterized the Nichols Report and Nichols Form as a unitary “Nichols Opinion” and argued that the Appeals Council’s different treatment (chronological relevance vs. materiality) was arbitrary and unlawful.

The Eleventh Circuit disagreed:

• Drawing on Tieniber, the court refused to infer that silence about newness or materiality meant that the Appeals Council had affirmatively “found” those elements satisfied.
• Because there was no clearly implied finding, the court held that the Appeals Council’s selective focus on certain criteria (chronological relevance for the Report; reasonable probability for the Form) did not create internal inconsistency.

2. The Chenery Argument and the Role of the District Court

Mr. Minton next argued that under Chenery and Owens, the district court had improperly supplied post hoc rationales to justify the Appeals Council’s denial.

The Eleventh Circuit’s response was straightforward:

• Owens prevents the Appeals Council from inventing after‑the‑fact reasons for an ALJ’s decision when the ALJ has not articulated them. It does not limit a reviewing court’s ability to supply reasons in support of the Appeals Council’s decision denying review.
• In contrast to ALJs, who “must articulate some basis for [their] decision,” the Appeals Council is “not required to provide a detailed explanation when it denies review” (Mitchell).
• Therefore, reviewing courts may look to the whole record, including the new evidence, and independently determine whether the regulatory criteria for Appeals Council review were met.

The court thus rejected any attempt to extend Chenery to bar such judicial reasoning where the Appeals Council has no duty to explain its denial in detail.

3. Materiality and the “Reasonable Probability” Standard

The heart of the opinion is its application of the materiality standard. The court framed the question as:

whether the additional evidence showed a “reasonable probability that it would change the outcome of the [ALJ’s] decision.” 20 C.F.R. § 404.970(a)(5).

The court adopted the reasoning of Reynolds and Spurgeon, stating, in substance, that new evidence does not meet this standard where:

• it contradicts other record evidence; and
• is inconsistent with its own comprehensive evaluation.

Applying that reasoning to the Nichols materials, the court identified three major problems:

a. Internal Inconsistencies

The court highlighted clear conflicts within the Nichols Report and between the Report and the Form. For example:

• The Nichols Report noted that Mr. Minton was neat and clean on examination, consistent with Dr. Fleming’s observation of adequate personal hygiene. Yet the Nichols materials concluded that he “could not adhere to basic standards of neatness and cleanliness.”
  This was both:
  • internally inconsistent; and
  • contradicted by other record evidence.
• The Report observed that Mr. Minton’s affect was appropriate, thought processes were normal, judgment and insight were good, and memory functions were “grossly intact.” Yet the Form alleged severe memory‑based and social‑behavior limitations.

In light of these contradictions, and given that an ALJ is “free to reject any physician’s opinion when the record as a whole supports a contrary conclusion” (Sryock), the court found that the Nichols materials did not create a reasonable probability of altering the ALJ’s decision.

b. Lack of Explanation and Supporting Rationale

The court also criticized the Nichols Opinion – particularly the Form – for offering extreme functional limitations with minimal or no explanation. For instance:

• The Report stated that, beyond normal work breaks, Mr. Minton would likely be off task 20–30% of an 8‑hour day and would likely miss 10–12 days of work in a 30‑day period.
• The Form captured these limitations in fill‑in‑the‑blank format, without citing specific treatment notes, medical findings, or longitudinal data.

The court deemed this insufficient. Consistent with Spurgeon, evidence fails the materiality test when it does not explain the basis for the enumerated limitations or connect them to objective medical evidence.

c. Cumulative Nature of the Evidence

Finally, the court noted that many aspects of the Nichols Report were consistent with evidence already presented to the ALJ. To the extent the Report merely reiterated or recast existing evidence regarding, for example, panic symptoms or memory complaints:

• it was cumulative and therefore not material under Mitchell.

In other words, even if some of Dr. Nichols’s observations lined up with prior records, they did not move the needle; the ALJ had already considered similar evidence and still concluded Mr. Minton was not disabled.

4. Decision Not to Reach Chronological Relevance

Because materiality is a necessary condition for Appeals Council review under § 404.970(a)(5), once the court concluded that the Nichols materials were not material, there was no need to address chronological relevance.

The court therefore explicitly declined to reach Mr. Minton’s fourth argument – whether the Nichols Report related back to the relevant time period – noting that, even assuming chronological relevance, the outcome would remain the same.

V. Complex Concepts Simplified

1. What Is the Appeals Council and What Does It Do?

After an ALJ issues a decision in a Social Security disability case, the claimant may ask the Appeals Council to review that decision. The Appeals Council sits within the SSA and serves as an internal appellate body.

The Appeals Council can:

• Deny review (leaving the ALJ’s decision as the final agency decision);
• Grant review and issue its own decision; or
• Remand the case to an ALJ for further proceedings.

Importantly, the Appeals Council can consider new evidence that was not before the ALJ, but only (under § 404.970(a)(5)) if it is:

• New – not previously submitted and not duplicative;
• Material – reasonably likely to change the outcome;
• Chronologically relevant – related to the period before or on the date of the ALJ’s decision.

2. “New,” “Material,” and “Chronologically Relevant” Evidence

These are technical but crucial concepts:

• New – Evidence is “new” if it was not part of what the ALJ considered and is not just a duplicate or re‑packaged version of what was already in the record.
• Material – In Social Security practice, evidence is “material” if it creates at least a “reasonable probability” (formerly articulated as “reasonable possibility”) that the ALJ would reach a different conclusion if the evidence were considered.
• Chronologically relevant – Evidence is “chronologically relevant” if it concerns the claimant’s condition during the time the ALJ was deciding the case, not solely about deterioration or events that happened later.

3. Residual Functional Capacity (RFC) and “Light Work”

Residual Functional Capacity (RFC) is what a claimant can still do, physically and mentally, on a regular and continuing basis despite their impairments. It is not a medical term but a legal/administrative finding that synthesizes medical and nonmedical evidence.

Light work, under SSA rules, typically involves:

• lifting up to 20 pounds occasionally and 10 pounds frequently;
• a good deal of standing or walking (often about 6 hours in an 8‑hour day); or
• other jobs that require a comparable amount of exertion.

If a claimant retains the RFC for light work, many jobs may still exist in significant numbers in the national economy that they can perform, making it difficult to establish disability.

4. The Chenery Doctrine and “Post Hoc Rationalization”

The Chenery doctrine, from SEC v. Chenery Corp., requires courts to evaluate an agency’s decision based on the reasons the agency itself gave, not on entirely new justifications invented during litigation. This prevents courts from rewriting agency decisions to save them.

In Social Security cases, this usually applies to ALJ decisions: if an ALJ denies benefits without adequately explaining why certain evidence was discounted, a reviewing court generally cannot “fill in the gaps” by inventing its own rationale.

However, as Minton clarifies:

• The Appeals Council, when it denies review, is not required to provide a detailed rationale (Mitchell);
• Therefore, courts may review the record and state their own reasons for concluding that the Appeals Council’s denial of review was lawful, without violating Chenery.

5. “Check‑Box” or “Fill‑in‑the‑Blank” Medical Forms

In disability cases, physicians sometimes complete very short forms that ask for:

• yes/no answers to questions about limitations; and
• estimates of time off task or days absent per month, with little or no narrative explanation.

Courts often view such forms skeptically, especially when:

• they are not supported by treatment notes or objective findings;
• they conflict with more comprehensive narrative evaluations by the same provider; or
• they contradict other medical evidence the ALJ found persuasive.

In Minton, as in Reynolds and Spurgeon, the Eleventh Circuit treated Dr. Nichols’s one‑page mental health statement as weak, unpersuasive, and not material due to these features.

VI. Impact and Broader Significance

A. For Claimants and Their Counsel

The decision carries several practical implications for future Social Security appeals in the Eleventh Circuit:

• High Bar for Materiality of New Evidence.
  Claimants should not assume that any new medical opinion triggers Appeals Council review. Evidence must:
  • add genuinely new information (not merely reiterate past complaints);
  • be clearly tied to the relevant timeframe; and
  • be well‑explained and supported by medical findings or treatment history.
• Weakness of Stand‑Alone Check‑Box Forms.
  Minton, like Reynolds and Spurgeon, signals that the Eleventh Circuit views Dr. Nichols’s short forms as particularly suspect when they:
  • conflict with her own narrative evaluations; or
  • lack explanation and documentation.
  Counsel relying on similar forms should be prepared to show:
  • how the form is consistent with longitudinal treatment records;
  • why any apparent internal inconsistencies are not truly inconsistent; and
  • how, concretely, the new evidence would reasonably change the ALJ’s RFC or step‑five analysis.
• Limited Power of the Chenery Argument at the Appeals Council Stage.
  It will be difficult for claimants to win Appeals Council‑based remands by arguing that the Council’s written explanation was too short. Reviewing courts may step in to supply reasons consistent with the record without violating Chenery.

B. For ALJs and the SSA

The decision indirectly reinforces best practices for ALJs and the SSA:

• Robust Explanation by ALJs Remains Critical.
  Though the Appeals Council need not explain itself in detail when denying review, ALJs must still provide clear, reasoned decisions. Otherwise, Owens and Chenery can still require remand.
• Consistency and Documentation Matter.
  When ALJs articulate why they find certain opinions persuasive (e.g., Drs. Fleming and Ravello), those opinions can later serve as a bulwark against new, less‑explained contrary evidence at the Appeals Council level.

C. In the Broader Eleventh Circuit Social Security Jurisprudence

Though unpublished, Minton continues and consolidates trends in Eleventh Circuit Social Security law:

• Reinforcement of a stringent new‑evidence standard.
  The opinion aligns with Hargress, Washington, Mitchell, and Pupo in setting a high bar for Appeals Council remands based on new evidence.
• Refinement of the Chenery/Owens/Green distinction.
  It underscores the doctrinal distinction between:
  • an ALJ’s duty to articulate reasons (where Chenery has full force); and
  • the Appeals Council’s limited obligations when simply denying review (where Chenery does not prevent judicial supplementation of reasoning).
• Continuing skepticism toward unelaborated mental RFC forms.
  Minton fits squarely with Reynolds and Spurgeon in its treatment of Dr. Nichols’s mental health forms, signaling a broader judicial skepticism toward short, unsupported check‑box opinions as a basis for overturning disability denials.

VII. Conclusion: Key Takeaways

Michael A. Minton v. Social Security Administration, Commissioner is best understood not as a radical departure but as a clarifying, consolidating opinion within Eleventh Circuit Social Security law. It emphasizes:

1. No inference of “implicit findings” by the Appeals Council.
   Courts will not assume that, by addressing only one prong (e.g., chronological relevance), the Appeals Council has implicitly decided others (e.g., newness, materiality). Absent a clearly implied finding, silence is just silence.
2. Limited reach of Chenery at the Appeals Council stage.
   Because the Appeals Council is not required to provide a detailed explanation when it denies review, district courts and the Eleventh Circuit may supply reasons – grounded in the record – for affirming those denials without violating Chenery or Owens.
3. Strict application of the “reasonable probability” materiality standard.
   New evidence must do more than add color or repeat existing allegations; it must be:
   • consistent internally and with the record;
   • supported by explanation and medical documentation; and
   • plausibly outcome‑determinative.
4. Skepticism toward unsupported check‑box mental opinions.
   Dr. Nichols’s materials failed because they were internally inconsistent, conflicted with her own examination findings and other medical evidence, lacked explanatory support, and were in some respects cumulative of the record already before the ALJ.

In the broader context of Social Security disability litigation, Minton reinforces that securing a remand based on new evidence at the Appeals Council level requires carefully constructed, well‑documented, and clearly relevant submissions. Attorneys must ensure that such evidence is not only new and temporally pertinent but also cogently explained, clinically grounded, and sufficiently powerful to create a genuine likelihood of altering the ALJ’s conclusion.