Waheed v. Social Security Administration
Sehra Waheed v. Social Security Administration; Frank Bisignano-Commissioner of the Social Security Administration
- Laura Swain
- 1:25-cv-07988
- U.S. District Court · Southern District of New York
- 2
In Sehra Waheed v. Social Security Administration, Judge Swain dismissed the duplicate disability-benefits case without prejudice and denied fee-free appeal status.
Sehra Waheed’s later-filed Social Security disability-benefits case was dismissed without prejudice because an identical case was already pending. Her separate pending case, No. 25-CV-7751 (ALC), was not dismissed by this order.
What happened
In Sehra Waheed v. Social Security Administration, Sehra Waheed, representing herself, filed a case under a federal law governing court review of Social Security disability-benefits decisions. The court said she had already filed the identical complaint in another case that was still pending before Judge Andrew L. Carter, Jr.
Because the two cases raised the same claims, the court found that litigating this later case would serve no useful purpose. The court therefore dismissed this complaint as duplicative and stated that the dismissal was without prejudice to Waheed’s pending case, No. 25-CV-7751 (ALC).
Judge Laura Taylor Swain, the Chief United States District Judge, also certified that an appeal would not be taken in good faith and denied permission to appeal without paying filing fees. The Clerk was directed to enter judgment dismissing this case without prejudice.
The detailed version
- Waheed v. Social Security Administration · No. 1:25-cv-07988
- Laura Swain
- Sept. 26, 2025
Background
Sehra Waheed, who was appearing without a lawyer, brought this action under 42 U.S.C. § 405(g) concerning an application for Social Security disability benefits. The opinion states that Waheed had previously submitted the identical complaint to the same court. That earlier case remained pending before Judge Andrew L. Carter, Jr., under docket number 25-CV-7751 (ALC).
Reason for dismissal
The court explained that a person generally may not maintain two separate actions in the same court, against the same defendant, concerning the same subject matter at the same time. Because this complaint raised the same claims as the pending earlier case, the court concluded that no useful purpose would be served by litigating the duplicate lawsuit.
Ruling
The court dismissed the complaint as duplicative, without prejudice to Waheed’s pending case under docket number 25-CV-7751 (ALC). The Clerk of Court was directed to enter judgment dismissing this case without prejudice. The order did not decide the merits of Waheed’s Social Security disability-benefits claims.
The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied permission to appeal without paying the required fees. A footnote states that Waheed had not filed an application to proceed without paying fees or paid the filing fees for this action; because the case was dismissed without prejudice, the court did not direct her to correct that deficiency.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.