Wood v. Commissioner of the Social Security Administration
- George Daniels
- 1:19-cv-01086
- U.S. District Court · Southern District of New York
- 3
In Wood v. Commissioner, Judge Daniels upheld the denial of MAC’s benefits, denying remand and granting the Commissioner’s motion for judgment on the pleadings.
The ruling affected MAC’s claim for Supplemental Security Income benefits and Wood’s request for further administrative proceedings on MAC’s behalf. It left the administrative denial in place.
What happened
Lakiesha Wood sued on behalf of her minor child, MAC, seeking review of an administrative law judge’s decision denying MAC Supplemental Security Income benefits. Wood asked the court to send the case back for further administrative proceedings.
Wood argued that the administrative law judge had not adequately developed the record and that MAC’s impairments met or equaled the requirements of a listed impairment. The Commissioner asked for judgment on the pleadings.
Judge George B. Daniels found no error in the magistrate judge’s report, overruled Wood’s objections, denied the motion to remand, and granted the Commissioner’s motion for judgment on the pleadings.
The detailed version
- Wood v. Commissioner of the Social Security Administration · No. 1:19-cv-01086
- George Daniels
- Mar. 24, 2020
Background
Lakiesha Wood brought the action on behalf of her minor child, MAC, under the Social Security Act. She sought review of an administrative law judge’s decision denying MAC Supplemental Security Income benefits. Wood moved for a remand, meaning that she asked the court to send the matter back for additional administrative proceedings. The Commissioner moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).
Magistrate Judge Sarah L. Cave recommended denying Wood’s motion and granting the Commissioner’s motion. Wood filed timely objections, and the Commissioner responded.
Court’s analysis
The district court explained that it must independently review the portions of a magistrate judge’s report that are properly challenged. It reviews portions supported only by conclusory, general, or repetitive objections for clear error, meaning an obvious mistake after reviewing the record.
The court found that Wood’s objections repeated arguments made before Magistrate Judge Cave. Wood argued that Administrative Law Judge Vincent M. Cascio failed to adequately develop the record and that MAC’s impairments met, medically equaled, or functionally equaled the criteria of Listing 112.05. After reviewing the report and the objections, the court found no error, clear or otherwise.
Disposition
The court adopted Magistrate Judge Cave’s report in full and overruled Wood’s objections. Judge George B. Daniels denied Wood’s motion to remand and granted the Commissioner’s motion for judgment on the pleadings. The clerk was directed to close the motions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.