D'Amato v. Commissioner of the Social Security Administration
- Valerie Caproni
- 1:18-cv-06998
- U.S. District Court · Southern District of New York
- 3
In D'Amato v. Commissioner, Judge Caproni granted D'Amato’s motion, denied the Commissioner’s motion, and remanded the case.
Alexandria D’Amato and the Commissioner of the Social Security Administration; the case returns to the Social Security Administration for further proceedings.
What happened
D'Amato v. Commissioner concerns Alexandria D’Amato’s challenge to the denial of her applications for disability insurance benefits and Supplemental Security Income. Both sides asked the court to rule in their favor based on the existing court record.
A magistrate judge recommended granting D’Amato’s motion, denying the Commissioner’s motion, and sending the case back for further proceedings. Neither party timely objected to that recommendation.
Judge Caproni adopted the recommendation, granted D’Amato’s motion, denied the Commissioner’s motion, and remanded the case. The court said the administrative law judge failed to give adequate reasons for rejecting D’Amato’s treating neurologist’s opinions about her functional limitations.
The detailed version
- D'Amato v. Commissioner of the Social Security Administration · No. 1:18-cv-06998
- Valerie Caproni
- Feb. 14, 2020
Background
Alexandria D’Amato sought review under the Social Security Act of the denial of her applications for disability insurance benefits and Supplemental Security Income. The parties filed competing motions for judgment on the pleadings, asking the court to decide the case based on the existing administrative record.
On January 30, 2020, Magistrate Judge Moses issued a Report and Recommendation (R&R). The R&R recommended granting D’Amato’s motion, denying the Commissioner’s motion, and remanding the case for further proceedings. Neither party filed timely objections.
Court’s Analysis
The court explained that it reviews a Social Security decision to determine whether substantial evidence supports the decision and whether the correct legal standards were applied. “Substantial evidence” means relevant evidence that a reasonable person could accept as adequate to support a conclusion.
Because there were no timely objections to the R&R, the court reviewed it for clear error on the face of the record. The court found no clear error and adopted the R&R in full. It stated that the administrative law judge violated the treating physician rule by failing to provide good reasons for rejecting the opinions of D’Amato’s treating neurologist concerning her functional limitations.
Disposition
The court granted Plaintiff’s motion for judgment on the pleadings, denied Defendant’s motion for judgment on the pleadings, and remanded the case for further proceedings consistent with the R&R. The court did not award benefits in this order. It also stated that the Commissioner’s failure to file adequate objections to the R&R precluded appellate review of the decision. The Clerk was directed to terminate all open motions and close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.