J.J. v. Commissioner

Background

J.J. brought this action under Section 405(g) of the Social Security Act, seeking judicial review of a final decision denying an application for disability insurance benefits. The complaint identified an adverse hearing examiner’s decision dated October 16, 2024, which became the Commissioner’s final decision for judicial-review purposes on June 10, 2025. The court had separately granted J.J. permission to proceed without paying the filing fee.

Because J.J. received that filing-fee status, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2)(B). That law requires dismissal if a complaint is frivolous, malicious, fails to state a claim for relief, or seeks monetary relief from an immune defendant. The court explained that Social Security complaints are subject to this screening requirement and that the failure-to-state-a-claim standard is the same as the standard used for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6).

Screening Analysis

The court found that the complaint did not seek damages from the Commissioner and instead sought reversal of the benefits decision. It also found that the Commissioner was not immune from the requested relief because Section 405(g) authorizes judicial review of qualifying final decisions. The complaint had an arguable legal and factual basis, so it was not frivolous. The court also found no indication that it was malicious.

The court applied Supplemental Rule 2(b)(1), which requires a Social Security complaint to identify the legal basis for the action, the final decision being reviewed, the name and county of residence of the person claiming benefits, the person whose earnings record supports the claim, and the type of benefits sought. The complaint satisfied the requirements concerning the legal basis, the final decision, and the type of benefits—disability insurance benefits.

The complaint did not, however, clearly identify J.J. The name in the complaint differed from the name appearing on other filings, and the complaint did not explain the discrepancy. The court said this uncertainty prevented it from determining the identity relevant to the final decision under review. The complaint also did not identify the person whose earnings record supported the benefits claim. The court therefore concluded that the complaint failed to meet the minimum pleading requirements for stating a claim for relief.

Disposition

Judge Peter H. Kang ordered that the complaint be dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B) for failure to adequately state a claim for relief. The court granted J.J. leave to file an amended complaint correcting the identified problems by November 12, 2025, unless the deadline was extended by court order. The court stated that failure to amend, or inability to cure the deficiencies, could result in further consequences, including a recommendation that the action be dismissed in whole or in part.