Benjamin S. v. Bisignano

Background

Benjamin S. filed a Motion for Summary/Default Judgment in Favor of Plaintiff. He asked the court to reverse the Commissioner’s denial of his Social Security benefits because the Commissioner allegedly failed to file the certified administrative record by the court-ordered deadline of April 7, 2026. Benjamin S. also asserted that he received no notice from the Commissioner about the documents filed with the court.

The court had previously extended the Commissioner’s deadline to file the certified administrative record until April 7, 2026. The Commissioner filed the record on that date. The Commissioner later filed a certificate of service stating that a copy of the documents had been mailed by first-class mail to Benjamin S. on April 27, 2026.

Analysis

The court concluded that the Commissioner complied with the order because the administrative record was filed by April 7, 2026. The court therefore recommended denying the part of Benjamin S.’s motion seeking reversal of the benefits denial based on an allegedly late filing.

The court also recommended denying any request for default judgment. It explained that Benjamin S. had not first obtained an entry of default from the Clerk of Court, which Federal Rule of Civil Procedure 55(a) requires before a party may seek default judgment.

Disposition and next deadline

The Report and Recommendation recommends that Benjamin S.’s Motion for Summary/Default Judgment in Favor of Plaintiff be DENIED. Separately, Judge Elizabeth Cowan Wright ordered Benjamin S. to file his opening brief on or before June 1, 2026. The court stated that he could file a motion requesting more time if necessary.

The document is a magistrate judge’s Report and Recommendation, not a district-court order or judgment, and it is not directly appealable to the Eighth Circuit. The notice states that a party may file specific written objections within 14 days after being served with the recommendation, subject to the District of Minnesota’s rules.