September L. v. Bisignano
- Laura Provinzino
- 0:25-cv-00331
- U.S. District Court · District of Minnesota
- 2
In September L. v. Bisignano, Judge Provinzino adopted a magistrate judge's recommendation and remanded the Social Security disability benefits denial back to the Commissioner for further proceedings.
People who have been denied Social Security disability insurance benefits and are seeking judicial review of that denial, particularly those whose cases involve non-severe mental impairments that may not have been fully considered during the agency's review process.
What happened
In September L. v. Bisignano (No. 25-cv-331, D. Minn.), a woman named September L. sued to challenge the Social Security Commissioner's decision denying her application for disability insurance benefits. She asked the court to send the case back to the agency for a new review, while the Commissioner asked the court to uphold the original denial and dismiss the complaint.
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation on January 29, 2026, recommending that the case be sent back to the Commissioner for further proceedings and that the Commissioner's request to dismiss be denied. Neither party objected to those recommendations, so the reviewing court applied a standard that looks only for clear error.
Judge Laura M. Provinzino found no clear error in the Report and Recommendation and adopted it in full. The court granted September L.'s request for remand, denied the Commissioner's request to dismiss the complaint, and ordered the case returned to the Commissioner for further administrative proceedings — specifically directing the Commissioner to account for September L.'s non-severe mental impairments and address her other claimed errors on remand.
The detailed version
- September L. v. Bisignano · No. 0:25-cv-00331
- Laura M. Provinzino
- Feb. 23, 2026
Background
Plaintiff September L. brought this action in the United States District Court for the District of Minnesota seeking judicial review of a final decision by the Commissioner of Social Security, Frank Bisignano, denying her application for disability insurance benefits (DIB). DIB provides monthly payments to workers who become unable to work due to a qualifying medical impairment.
Parties' Positions
September L. asked the court to vacate the Commissioner's denial and remand (send back) the case to the agency for further administrative proceedings. The Commissioner opposed that request and asked the court to affirm his decision and dismiss the complaint.
Report and Recommendation
After briefing, United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation (R&R) on January 29, 2026. The R&R recommended granting September L.'s remand request and denying the Commissioner's request to dismiss. Neither party filed objections to the R&R.
Standard of Review
When no party objects to a magistrate judge's R&R, the district court reviews it only for clear error. See Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996). Judge Provinzino applied that standard here.
Ruling
Judge Provinzino found no clear error and adopted the R&R in full. The court:
- Adopted the R&R (ECF No. 14);
- Granted September L.'s request for remand of the Commissioner's decision;
- Denied the Commissioner's request that the complaint be dismissed; and
- Remanded the matter to the Commissioner under sentence four of 42 U.S.C. § 405(g) — a statutory provision authorizing courts to remand Social Security cases to the agency for further proceedings — directing the Commissioner to account for September L.'s non-severe mental impairments and to address the other errors she raised.
The court ordered judgment to be entered accordingly.
Effect of the Remand Instruction
A footnote in the order specifies that on remand the Commissioner must address September L.'s non-severe mental impairments and the other claims of error she raised, as detailed in the R&R.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.