Danielle M. K. v. Kijakazi

Background

Danielle M. K., identified as the parent and natural guardian of D.E.K., sought judicial review of a December 2019 decision by the Social Security Administration’s Appeals Council denying a claim for Supplemental Security Income. The Commissioner was required to answer the complaint and file the administrative record by April 24, 2020.

The Commissioner moved to stay, or temporarily pause, the proceedings. The motion stated that the Social Security Administration had suspended in-office services because of the COVID-19 pandemic and that the Commissioner therefore could not complete critical in-person physical tasks needed to prepare the case transcript. Danielle M. K. did not oppose the motion.

Court’s analysis

The court explained that federal courts have authority to control the timing of cases on their dockets, but the party requesting a stay must show that the stay is needed. The court also considered the competing interests because a stay can harm the party opposing it.

The court found that the Commissioner had shown good cause for a stay and that Danielle M. K. had not argued that a stay would prejudice her. However, the court emphasized the importance of Social Security benefits to recipients and the substantial time these cases already take. It therefore concluded that an indefinite stay of all proceedings was not warranted.

Ruling

Magistrate Judge Tony N. Leung ordered that the Commissioner’s Motion for Stay of Proceedings was GRANTED IN PART AND DENIED IN PART. The matter was stayed for 60 days from the date of the order, and the stay was to lift automatically unless the court entered a further order. The Commissioner could reapply to extend the stay if the Social Security Administration believed more time was necessary because of the COVID-19 pandemic. The order addressed scheduling only and did not decide the merits of the claim for benefits.