Chambless v. Berryhill

Background

Tara Chambless sought review under the Social Security Act of the denial of her application for Supplemental Security Income. Chambless and Nancy A. Berryhill, the Acting Commissioner of Social Security, filed cross-motions for judgment on the pleadings.

On April 20, 2020, Magistrate Judge Cott issued a Report and Recommendation recommending that Chambless’s motion be granted, the Commissioner’s motion be denied, and the case be remanded for further proceedings. Neither party objected to the recommendation.

Court’s analysis

The court explained that it reviews Social Security decisions to determine whether substantial evidence supports the Commissioner’s decision and whether the correct legal standards were used. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

Because neither party objected to the Report and Recommendation, the court reviewed it for clear error on the face of the record. The court found no clear error. It agreed with the recommendation that the Administrative Law Judge failed to fully develop Chambless’s medical history when the record had deficiencies. The court stated that the Administrative Law Judge had a duty to do so.

Disposition

The court adopted the Report and Recommendation in full. It granted Chambless’s motion for judgment on the pleadings, denied the Commissioner’s cross-motion for judgment on the pleadings, and remanded the case for further proceedings consistent with the recommendation. The Clerk was directed to terminate the open motions and close the case. The court also stated that the Commissioner’s failure to file adequate objections to the recommendation precluded appellate review of the decision. The opinion does not state that benefits were awarded.