Randy M. v. O'Malley

Background

Randy M. brought this action under 42 U.S.C. § 405(g) of the Social Security Act to seek judicial review of a final decision denying his application for supplemental security income based on disability. The complaint identified Martin O’Malley as the Acting Commissioner of the Social Security Administration. The court had previously granted Randy M. permission to proceed without paying the filing fee.

Mandatory screening

Because Randy M. was proceeding without paying the filing fee, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2)(B). The court had to dismiss the complaint if it was frivolous or malicious, failed to state a claim on which relief could be granted, or sought monetary relief from a defendant immune from that relief.

The court applied Supplemental Rule 2 for Social Security actions under § 405(g). That rule requires a complaint to state that it arises under § 405(g), identify the final decision being challenged, state the name and county of residence of the person seeking benefits, identify the person whose wage record is involved, and state the type of benefits claimed. A short statement explaining the grounds for relief may be included but is not required.

The court found that the complaint met these requirements. It referred to § 405(g), identified an unfavorable administrative decision dated December 20, 2023, stated that the decision became final on June 5, 2024, identified Randy M. and Alameda County, California, and referred to Title II and/or Title XVI disability benefits. The court also found that the requested judgment reversing the benefits decision was not a damages request and that the Commissioner was not immune from the requested relief.

Ruling

The court concluded that the complaint was not frivolous or malicious, did not fail to state a claim, and did not seek monetary relief from an immune defendant. It ordered that the complaint not be dismissed under § 1915(e)(2)(B). The court stated that this screening determination was without prejudice to later decisions on the merits after the Commissioner appears and the parties present further arguments, records, or other matters through the required procedures. The court also ordered electronic notice of the case’s commencement to the appropriate Social Security Administration and United States Attorney offices; the plaintiff did not have to serve a summons and complaint under the ordinary civil-service rule.