Lee v. Kijakazi

Background

Cathrine R. Lee filed the action after alleging that she requested a copy of her disability file and medical records from the Social Security Administration but received no response. The Commissioner moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which allows dismissal for lack of subject-matter jurisdiction.

Court’s analysis

The Commissioner made a factual challenge to jurisdiction, arguing that the case was moot because the agency had already released the requested records. A case is moot when there is no longer a live dispute for the court to resolve. The Commissioner supported the challenge with a declaration from an agency assistant district manager stating that the agency sent the requested records to the address Lee had listed in her request. The court also directed service of the motion at that address and at another address Lee had provided.

Because whether Lee received the records affected both subject-matter jurisdiction and the substance of her requested relief, the court treated the motion to dismiss as a motion for summary judgment. Summary judgment is appropriate when the undisputed material facts show that a party is entitled to judgment as a matter of law. Lee did not respond to the motion, so the Commissioner’s factual assertions were undisputed.

Disposition

The court concluded that Lee had not met her burden of establishing that the court had jurisdiction over the action. It held that the defendant was entitled to judgment in his favor and entered judgment for the defendant. The opinion does not expressly state that Lee personally confirmed receiving the records; it states that the agency’s assertions that the records were sent were undisputed.