Franz v. Bisignano
- Jeffrey Bryan
- 0:24-cv-02795
- U.S. District Court · District of Minnesota
- 2
In Michelle F. v. Bisignano, Judge Bryan adopted a magistrate judge's recommendation and dismissed the Social Security benefits appeal without prejudice.
People who have been denied Social Security benefits and are seeking judicial review of that decision in the District of Minnesota, particularly those whose cases are decided on a magistrate judge's report and recommendation with no objections filed.
What happened
Michelle F. sued Frank Bisignano, Commissioner of Social Security, seeking court review of the agency's decision to deny her Social Security benefits. A magistrate judge reviewed the case and issued a Report and Recommendation (R&R) on July 31, 2025, recommending that Michelle F.'s request for relief be denied and that the Commissioner's decision be upheld. Neither side objected to the R&R within the allowed time.
Because no objections were filed, Judge Jeffrey M. Bryan reviewed the R&R only for clear error — a lower level of scrutiny than a full review. The court found no clear error in the magistrate judge's analysis or conclusions.
Judge Bryan adopted the R&R and dismissed the case without prejudice, meaning Michelle F. is not necessarily permanently barred from refiling, though the opinion does not discuss what further steps might be available to her.
The detailed version
- Franz v. Bisignano · No. 0:24-cv-02795
- Jeffrey M. Bryan
- Aug. 28, 2025
Background
Plaintiff Michelle F. brought this action against Frank Bisignano in his capacity as Commissioner of Social Security, challenging the agency's decision to deny her Social Security benefits. The case was referred to United States Magistrate Judge Shannon G. Elkins for a Report and Recommendation (R&R) — a magistrate judge's written analysis and proposed ruling that the district court judge then reviews.
Report and Recommendation
On July 31, 2025, Magistrate Judge Elkins issued an R&R recommending that Michelle F.'s request for relief be denied and that the Commissioner's decision to deny benefits be upheld. Neither party filed objections to the R&R, and the deadline for doing so passed without any response.
Standard of Review
When no party objects to an R&R, the district court reviews it for "clear error" under Federal Rule of Civil Procedure 72(b). This is a deferential standard: the court will accept the magistrate judge's conclusions unless they contain an obvious mistake. The court cited Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996), as authority for this standard.
Ruling
Finding no clear error in the R&R, Judge Bryan adopted it in full and dismissed the action without prejudice. The court directed that judgment be entered accordingly. The opinion does not explain why dismissal without prejudice — rather than a denial of relief on the merits — was the chosen disposition, nor does it address what further proceedings, if any, remain available to the plaintiff.
Note on Party Name
The court's footnote explains that this District uses only the first name and last initial of non-governmental parties in Social Security matters, which is why the plaintiff is identified as "Michelle F." throughout the record.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.