Victoria H. v. Bisignano
- Elizabeth Wright
- 0:25-cv-00847
- U.S. District Court · District of Minnesota
- 2
In Victoria H. v. Bisignano, Judge Bryan adopted a magistrate's recommendation and granted plaintiff Victoria H.'s motion to reverse the Social Security Commissioner's denial of disability insurance benefits.
People who have been denied Social Security Disability Insurance Benefits and are seeking federal court review of that denial, particularly in the District of Minnesota.
What happened
In Victoria H. v. Bisignano (No. 25-CV-00847), plaintiff Victoria H. challenged the Social Security Commissioner's decision to deny her Title II Disability Insurance Benefits. A magistrate judge issued a Report and Recommendation on January 30, 2026, recommending that the court reverse the Commissioner's denial and award benefits, and that the Commissioner's request to affirm the denial and dismiss the case be denied. Neither party objected to that recommendation.
Because no objections were filed, Judge Jeffrey M. Bryan reviewed the magistrate's Report and Recommendation only for clear error — a more limited form of review than if objections had been raised. Finding no clear error, the court adopted the Report and Recommendation in full.
Judge Bryan granted Victoria H.'s motion, denied the Commissioner's motion, and dismissed the action without prejudice. The court ordered that judgment be entered accordingly.
The detailed version
- Victoria H. v. Bisignano · No. 0:25-cv-00847
- Elizabeth Wright
- Feb. 17, 2026
Background
Plaintiff Victoria H. brought this action challenging the Social Security Commissioner's decision to deny her Title II Disability Insurance Benefits. Title II of the Social Security Act provides disability insurance benefits to eligible workers who become disabled. The Commissioner — defendant Frank Bisignano — had denied Victoria H.'s benefits claim, and she sought federal court review, asking the court to reverse that denial and award benefits directly. The Commissioner cross-moved to have the denial affirmed and the case dismissed.
Report and Recommendation
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation (R&R) on January 30, 2026 (Doc. No. 17). The R&R recommended: (1) granting Victoria H.'s request to reverse the Commissioner's denial and award benefits; and (2) denying the Commissioner's request to affirm the denial and dismiss the action.
Neither party filed objections to the R&R within the time permitted under District of Minnesota Local Rule 72.2(b)(1).
Standard of Review
When no timely objections are filed to a magistrate judge's R&R, the district court reviews it only for clear error, under Federal Rule of Civil Procedure 72(b) and Eighth Circuit precedent (citing Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996)). This is a more deferential standard than de novo (full independent) review, which would apply if objections had been made.
Ruling
Finding no clear error, Judge Bryan adopted the R&R in its entirety. The court:
- Adopted the R&R (Doc. No. 17).
- Granted Victoria H.'s motion (Doc. No. 9).
- Denied the Commissioner's motion (Doc. No. 14).
- Dismissed the action without prejudice.
The court ordered that judgment be entered accordingly.
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 "Victoria H." throughout.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.