Diaz v. Social Security Administration Disability
- Louis Stanton
- 1:20-cv-01551
- U.S. District Court · Southern District of New York
- 6
In Diaz v. Social Security Administration Disability, Judge Stanton dismissed Diaz’s fee-free complaint as frivolous and legally insufficient.
Edwin C. Diaz’s complaint was dismissed. The Social Security Administration, Dr. James Todd, Dr. Ann Monis, and Administrative Law Judge Jason Miller were the defendants named in the complaint; the court’s rulings protected the agency and the individual defendants from the claims described in this action.
What happened
In Edwin C. Diaz v. Social Security Administration Disability, Diaz, representing himself, sued the Social Security Administration’s disability office, two doctors, and Administrative Law Judge Jason Miller. He sought approval of Supplemental Security Income benefits and money damages, alleging that testimony and records in his disability proceedings were false or incomplete.
The court ruled that claims against the Social Security Administration were barred because federal agencies generally cannot be sued without the government’s consent. It also found no valid constitutional damages claim against the federal judge or the doctors: the judge was protected for actions taken in the proceedings, and witnesses were protected from lawsuits over their testimony. The court said Diaz’s disability case appeared not to have reached a final agency decision and noted that federal review may be available after that happens.
Judge Louis L. Stanton dismissed the complaint during review of Diaz’s fee-free filing, calling it frivolous and legally insufficient. The court declined to allow an amended complaint because it found that amendment would not fix the defects.
The detailed version
- Diaz v. Social Security Administration Disability · No. 1:20-cv-01551
- Louis Stanton
- Mar. 27, 2020
Background
Edwin C. Diaz filed the action without a lawyer and asked to proceed without paying filing fees upfront. The court granted that request on March 25, 2020. Diaz sued the “Social Security Administration Disability,” which the court presumed referred to the Social Security Administration’s Office of Disability Adjudication and Review, along with Dr. James Todd, Dr. Ann Monis, and Administrative Law Judge Jason Miller.
Diaz sought approval of his Supplemental Security Income application and monetary damages. He alleged that Todd and Monis gave false testimony, inserted false information into his disability case, wrongly described him as an alcoholic and as noncompliant with doctors, added medications he said he had never taken or been prescribed, and omitted seven years of medical information. He also alleged that Miller humiliated him during the proceedings and changed the meaning of his oral testimony in a written decision.
The opinion states that Diaz described the events as occurring in August and November 2018 at a Southern District of New York courthouse. A footnote says the court’s electronic records did not show that Diaz had an SSI-related action in that court and that the allegations instead appeared to concern administrative proceedings before Miller at the Social Security Administration’s disability office.
Legal standards
Because Diaz was proceeding without a lawyer and without paying filing fees upfront, the court was required to dismiss the complaint, or part of it, if it was frivolous, failed to state a legally valid claim, sought damages from an immune defendant, or fell outside the court’s authority. The court also had to interpret his allegations generously, but the complaint still had to provide enough factual detail to make a claim legally plausible.
Claims against the Social Security Administration
The court applied sovereign immunity, which generally prevents lawsuits against the federal government and its agencies unless the government has agreed to be sued. It held that Diaz’s claims against the disability office were effectively claims against the Social Security Administration and that no statute identified in the complaint waived the agency’s immunity. The court therefore dismissed those claims as frivolous, including any constitutional claims Diaz sought to bring against the agency.
Constitutional damages claims against the individual defendants
The court interpreted Diaz’s allegations as possibly asserting claims under Bivens, a limited legal theory allowing damages claims against certain federal officials for constitutional violations. The court explained that the Supreme Court has recognized that remedy only in three settings: unreasonable searches and seizures, certain employment-discrimination claims, and inadequate medical treatment of incarcerated people. It found that Diaz’s allegations about Social Security administrative proceedings did not present a viable Bivens claim.
The court separately held that Miller was immune from damages claims for conduct within his judicial responsibilities. It also held that Diaz failed to state a claim against Todd and Monis based on their testimony. If they were private individuals, the court said they generally could not be sued under Bivens. In addition, witnesses in judicial proceedings have civil immunity for their testimony, even when the testimony is alleged to be false.
Disposition
The court dismissed Diaz’s complaint as frivolous and for failure to state a claim on which relief could be granted. It declined to give him permission to amend because it found that the defects could not be cured by amendment. The order did not state that the dismissal was with or without prejudice. The court also noted that the Social Security Act permits federal-court review of a final decision by the Commissioner after a qualifying hearing and said Diaz could file such an action after his administrative proceedings concluded and he received a final decision.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.