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S.D.N.Y.Substantive rulingFiled Mar. 31, 2020

Barthelemy v. Commissioner of Social Security

Judge
Edgardo Ramos
Docket
1:18-cv-12236
Court
U.S. District Court · Southern District of New York
Pages
3
Social SecurityCivil Procedure
In one sentence

In Barthelemy v. Commissioner, Judge Ramos adopted the report, granted the Commissioner’s motion, denied Barthelemy’s motion, and closed the case.

Who this affects

Almanosta Barthelemy’s challenge to the denial of supplemental security income was unsuccessful. The Commissioner’s motion was granted, Barthelemy’s motion was denied, judgment was entered, and the case was closed.

What happened

In Barthelemy v. Commissioner of Social Security, Almanosta Barthelemy challenged the denial of her application for supplemental security income. The parties asked the court to rule based on their written submissions.

A magistrate judge recommended granting the Commissioner’s motion and denying Barthelemy’s motion. Barthelemy objected, but her objections repeated her earlier arguments and did not identify an error in the recommendation.

Judge Ramos found no clear error, adopted the recommendation in full, granted the Commissioner’s motion, denied Barthelemy’s motion, entered judgment, and closed the case.

The detailed version

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

Case
Barthelemy v. Commissioner of Social Security · No. 1:18-cv-12236
Judge
Edgardo Ramos
Date
Mar. 31, 2020

Background

Almanosta Barthelemy brought this action under 42 U.S.C. § 405(g), challenging the Commissioner of Social Security’s decision denying her application for supplemental security income. Both parties filed motions for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), asking the court to decide the case based on the existing pleadings and written submissions.

Report and Recommendation

On November 13, 2019, Magistrate Judge James L. Cott recommended granting the Commissioner’s motion and denying Barthelemy’s motion. The recommendation explained that the Commissioner’s decision should stand. Barthelemy filed an objection within the permitted time.

Court’s Analysis

The court determined that Barthelemy’s objection repeated the arguments she had already made and did not identify any fact that the recommendation had overlooked or misunderstood, or any legal conclusion that was erroneous. Because the objection was general and repetitive, the court reviewed the recommendation for clear error rather than reconsidering the disputed issues from the beginning. The court found no clear error.

Disposition

The court adopted the Report and Recommendation in its entirety. It granted the Commissioner’s Rule 12(c) motion and denied Barthelemy’s motion. The Clerk was directed to enter judgment, terminate the motions, and close the case.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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