Browne V. Richardson
Date:
A written report submitted by a non- testifying, non-examining physician who merely reviewed the written medical evidence could not alone constitute substantial evidence to support the Secretary's conclusion. The report "lacks the assurance of reliability that comes on the one hand from first-hand observation and professional examination or, on the other, from first-hand testimony subject to claimant's cross-examination. It is hearsay based on hearsay.