Yvette R. v. Commissioner of Social Security
- Jones
- 1:25-cv-00282
- U.S. District Court · Southern District of New York
- 15
In Venus Yvette R. v. Commissioner, Magistrate Judge Jones granted review and sent the benefits-termination decision back for further proceedings.
Venus Yvette R.’s claim for continued Disability Insurance Benefits and Supplemental Security Income benefits; the Commissioner must conduct further administrative proceedings.
What happened
In Venus Yvette R. v. Commissioner of Social Security, the agency ended Plaintiff Venus Yvette R.’s disability benefits after finding that her disability had ended on October 27, 2021. An Administrative Law Judge found medical improvement and determined that she could perform certain jobs.
Venus Yvette R. challenged that decision in federal court. She argued that the Administrative Law Judge did not properly develop and compare the medical evidence from the earlier decision awarding benefits with the later evidence supporting termination. The Commissioner argued that the existing treatment notes were enough and that substantial evidence supported the decision.
Magistrate Judge Gary R. Jones granted Venus Yvette R.’s motion for judgment on the pleadings and remanded the case for further administrative proceedings. The court found that the record did not include the actual 2014 disability determination or clearly include the complete evidence supporting it, and that the Administrative Law Judge did not adequately consider the earlier records.
The detailed version
- Yvette R. v. Commissioner of Social Security · No. 1:25-cv-00282
- Jones
- Nov. 4, 2025
Background
The Commissioner of Social Security found Plaintiff Venus Yvette R. disabled beginning November 23, 2006, and awarded benefits. The Social Security Administration later determined in 2014 that she remained disabled. On October 27, 2021, the agency determined that she was no longer disabled. After reconsideration was denied, Plaintiff requested a hearing before an Administrative Law Judge (ALJ).
At a November 14, 2023 hearing, Plaintiff testified without a lawyer, and a vocational expert also testified. On March 19, 2024, ALJ Mark Solomon found that Plaintiff’s disability and entitlement to benefits ended on October 27, 2021. The ALJ found medical improvement, determined that Plaintiff retained the capacity for a limited range of light work, and concluded that jobs existed in significant numbers that she could perform. The Appeals Council denied review on November 15, 2024, making the ALJ’s decision the Commissioner’s final decision.
Arguments and governing standard
Plaintiff sought review under 42 U.S.C. §§ 405(g) and 1383(c)(3), arguing that the ALJ had not properly developed the record or supported the termination decision. The Commissioner argued that the record’s 2013 and 2014 treatment notes satisfied the duty to develop the record and that substantial evidence supported the ALJ’s conclusion.
The court explained that when previously awarded disability benefits are terminated, the Commissioner must show medical improvement. The ALJ must compare the claimant’s current medical condition with the condition shown at the time of the most recent favorable decision finding the claimant disabled. The court reviews whether substantial evidence supports the Commissioner’s decision and whether the correct legal standard was applied.
Reason for remand
The court found that the administrative record contained 41 pages of treatment records from 2013 and 2014, but did not contain the actual October 2014 disability determination. The record also did not show that those treatment notes were the complete evidence supporting the 2014 decision. In addition, the ALJ’s decision referred to medical records beginning in 2020 and did not show that the ALJ reviewed or considered the records underlying the 2014 finding of disability.
The court held that this failure to develop and compare the relevant records required a remand. Because the missing earlier evidence affected the foundation for deciding whether medical improvement occurred, the court did not reach Plaintiff’s additional arguments about the ALJ’s efforts to obtain functional assessments from treating providers or Plaintiff’s opportunity to question the vocational expert.
Disposition
The court granted Plaintiff’s Motion for Judgment on the Pleadings and remanded the case for further administrative proceedings consistent with the Decision and Order. The Clerk was directed to enter final judgment in favor of Plaintiff and close the file. The opinion did not itself decide that Plaintiff remained entitled to benefits.
Read the full 15-page opinion on CourtListener, the free public archive maintained by the Free Law Project.