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's recommendation and remanded a Social Security disability benefits denial for further review.
People who have applied for Social Security disability insurance benefits and had their claims denied, particularly those whose cases involve questions about how the agency evaluated mental impairments that were found non-severe.
What happened
In September L. v. Frank Bisignano, Commissioner of Social Security (Case No. 25-cv-331), plaintiff September L. sued the Social Security Administration after it denied her application for disability insurance benefits. She asked the court to send the case back to the agency for reconsideration, while the Commissioner argued the denial should be upheld and the complaint dismissed.
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation on January 29, 2026, recommending that September L.'s request for remand be granted and the Commissioner's request to dismiss the complaint be denied. Neither party filed objections to that recommendation.
Because no objections were filed, Judge Laura M. Provinzino reviewed the Report and Recommendation only for clear error, found none, and adopted it in full. The court granted September L.'s request for remand, denied the Commissioner's request to dismiss the complaint, and sent the case back to the Social Security Administration for further administrative proceedings — specifically directing the agency to account for September L.'s non-severe mental impairments and address her other claimed errors.
The detailed version
- September L. v. Bisignano · No. 0:25-cv-00331
- Laura M. Provinzino
- Feb. 23, 2026
Background
Plaintiff September L. filed suit in federal district court seeking judicial review of a final agency decision by the Commissioner of Social Security, Frank Bisignano, denying her application for disability insurance benefits (DIB) — monthly payments available to workers who become unable to work due to a qualifying disability. September L. asked the court to vacate the Commissioner's decision and remand (send back) the matter to the agency for further proceedings. The Commissioner opposed remand and asked the court to affirm the denial and dismiss the complaint.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Elizabeth Cowan Wright, to whom the matter had been referred, issued a Report and Recommendation (R&R) on January 29, 2026. The R&R recommended granting September L.'s request for remand and denying the Commissioner's request to dismiss. The R&R further specified that on remand, the Commissioner must account for September L.'s non-severe mental impairments and address the other claims of error she raised.
Standard of Review
Because neither party filed objections to the R&R within the allotted time, Judge Provinzino applied a "clear error" standard of review — a deferential standard under which the court looks only for obvious mistakes in the magistrate judge's analysis, rather than reconsidering the issues from scratch. The court cited Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996) as authority for this standard.
Ruling
Finding no clear error, Judge Provinzino adopted the R&R in full. The court:
- Adopted the R&R (ECF No. 14);
- Granted September L.'s request for remand;
- Denied the Commissioner's request that the complaint be dismissed; and
- Remanded the matter to the Commissioner pursuant to sentence four of 42 U.S.C. § 405(g) — a statutory provision authorizing federal courts to reverse or affirm, with or without remanding, a Social Security decision — for further administrative proceedings consistent with the R&R.
The court directed that judgment be entered accordingly. On remand, the Commissioner is specifically directed to account for September L.'s non-severe mental impairments and address the other claimed errors she raised.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.