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D. Minn.Substantive rulingFiled June 14, 2024

Nathan L. v. O'Malley

Judge
Jerry Blackwell
Docket
0:23-cv-01310
Court
U.S. District Court · District of Minnesota
Pages
2
Social SecurityCivil Procedure
In one sentence

In Nathan L. v. O’Malley, Judge Blackwell granted Nathan L.’s request in part, denied the Commissioner’s request, vacated the decision, and remanded.

Who this affects

Nathan L. and the Commissioner of the Social Security Administration; the case returns to the Social Security Administration for further proceedings.

What happened

In Nathan L. v. O’Malley, Nathan L. asked the court for relief from the Social Security Commissioner’s final decision. The magistrate judge recommended relief, and no party objected to that recommendation.

The court found no clear error, accepted the recommendation, and granted Nathan L.’s request in part. It denied the Commissioner’s request, vacated the Commissioner’s final decision, and sent the case back for further administrative proceedings. The administrative law judge must reconsider whether Nathan L.’s residual functional capacity should include a further limit on brief and superficial interaction and, if needed, obtain new testimony from a vocational expert.

Judge Jerry W. Blackwell also ordered that the matter be dismissed with prejudice and directed that judgment be entered.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Nathan L. v. O'Malley · No. 0:23-cv-01310
Judge
Jerry W. Blackwell
Date
June 14, 2024

Background

Nathan L. challenged the final decision of the Commissioner of the Social Security Administration. United States Magistrate Judge Dulce J. Foster issued a Report and Recommendation on May 3, 2024. No objections were filed within the permitted time. The district court therefore reviewed the recommendation for clear error and found none.

Ruling

The court accepted the Report and Recommendation. It granted Nathan L.’s request for relief in part and denied the Commissioner’s request for relief. The court vacated the Commissioner’s final decision and remanded the case under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings consistent with the recommendation.

The recommendation directed the administrative law judge to provide a clear explanation of whether Nathan L.’s residual functional capacity should be further limited to brief and superficial interaction. To the extent necessary, the administrative law judge must also recall a vocational expert to address a new hypothetical based on any modified residual functional capacity.

The order additionally states that the matter is dismissed with prejudice and directs entry of judgment. The opinion does not provide the underlying facts of Nathan L.’s disability claim or explain the relationship between the remand and the dismissal with prejudice beyond the text of the order.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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