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S.D.N.Y.Substantive rulingFiled Mar. 30, 2020

Lent v. Berryhill

Judge
Edgardo Ramos
Docket
1:19-cv-01127
Court
U.S. District Court · Southern District of New York
Pages
2
Social SecurityCivil Procedure
In one sentence

In Lent v. Commissioner, Judge Ramos granted the Commissioner’s motion and denied Lent’s challenge to the denial of supplemental security income.

Who this affects

Richard H. Lent’s application for supplemental security income was denied, and the Commissioner of Social Security prevailed on the parties’ cross-motions for judgment on the pleadings.

What happened

In Lent v. Commissioner of Social Security, Richard H. Lent challenged the decision denying his application for supplemental security income. Both sides asked the court to rule based on the existing pleadings.

A magistrate judge recommended granting the Commissioner’s motion and denying Lent’s motion. Neither side objected within the required fourteen days, so the court reviewed the recommendation for clear error.

Judge Edgardo Ramos found no error, adopted the recommendation in full, granted the Commissioner’s motion, denied Lent’s motion, and closed the case. The opinion states that Lent’s failure to object prevents appellate review of the decision.

The detailed version

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

Case
Lent v. Berryhill · No. 1:19-cv-01127
Judge
Edgardo Ramos
Date
Mar. 30, 2020

Background

Richard H. Lent brought an action under 42 U.S.C. § 405(g) challenging the Commissioner of Social Security’s decision denying his application for supplemental security income. The parties filed cross-motions for judgment on the pleadings, asking the court to decide the case based on the pleadings and existing record.

Report and Recommendation

On March 3, 2020, Magistrate Judge Robert W. Lehrburger issued a Report and Recommendation recommending that the Commissioner’s motion be granted and Lent’s motion be denied. The parties were given fourteen days to file written objections, but neither party filed one.

Court’s analysis and ruling

Because there were no objections, the court reviewed the Report and Recommendation for clear error. It stated that it had carefully reviewed the recommendation and found no error, “clear or otherwise.” The court therefore adopted the Report and Recommendation in its entirety.

The Commissioner’s motion was granted, and Lent’s motion was denied. The court also directed the Clerk of Court to terminate the motions and close the case. The opinion states that Lent’s failure to object precludes appellate review of the decision.

Scope of the opinion

The excerpt does not describe the underlying reasons for the Commissioner’s denial of supplemental security income or the magistrate judge’s detailed merits analysis; it reports the district court’s adoption of the unobjected-to recommendation after clear-error review.

The authoritative version

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

Open opinion PDF →
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