Delgado v. Commissioner of Social Security
- George Daniels
- 1:18-cv-03960
- U.S. District Court · Southern District of New York
- 2
In Delgado v. Commissioner, Judge Daniels adopted a report, granted Delgado’s motion, denied the Commissioner’s motion, and remanded the disability-benefits case.
Ivan Delgado and the Commissioner of Social Security; the administrative denial of Delgado’s disability insurance benefits was remanded to the Social Security Administration for further proceedings.
What happened
In Delgado v. Commissioner of Social Security, Ivan Delgado asked the court to review an administrative law judge’s decision denying him disability insurance benefits. Delgado and the Commissioner each asked for judgment based on the court filings.
A magistrate judge recommended sending the case back to the Social Security Administration for further proceedings. She concluded that the administrative law judge made unsupported assumptions from consultants’ reports and relied heavily on those assumptions. Neither party objected to the recommendation.
Judge George B. Daniels found no error in the recommendation and adopted it in full. He granted Delgado’s motion for judgment on the pleadings, denied the Commissioner’s cross-motion, and remanded the matter for further proceedings.
The detailed version
- Delgado v. Commissioner of Social Security · No. 1:18-cv-03960
- George Daniels
- Feb. 27, 2020
Background
Ivan Delgado brought this action under the Social Security Act, asking the district court to review an administrative law judge’s decision denying his application for disability insurance benefits. Both Delgado and the Commissioner of Social Security moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), which allows judgment based on the parties’ written submissions when there is no material factual dispute requiring a trial.
Report and Recommendation
Magistrate Judge Debra Freeman recommended granting Delgado’s motion to the extent that the case be remanded to the Social Security Administration for further proceedings and denying the Commissioner’s cross-motion. She concluded that the administrative law judge made various assumptions based on consultants’ reports and relied heavily on those assumptions even though they were not supported by substantial evidence.
The parties filed no objections to the report. The district court therefore reviewed it for clear error, meaning an obvious mistake after reviewing the record. The court stated that it could accept, reject, or modify the magistrate judge’s recommendations.
Ruling
The court found Magistrate Judge Freeman’s analysis well reasoned and supported by the facts and law. It found no error, clear or otherwise, adopted the report in full, and granted Delgado’s motion for judgment on the pleadings. It denied the Commissioner’s cross-motion and remanded the matter to the Social Security Administration for further proceedings. The order did not award benefits directly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.