Fields v. Commissioner of Social Security
- Analisa Torres
- 1:19-cv-01423
- U.S. District Court · Southern District of New York
- 1
In Fields v. Commissioner of Social Security, Judge Torres denied the Commissioner’s motion and remanded the case to the administrative law judge for further review.
Alisa Renee Fields and the administrative law judge handling her Social Security claim; the remand requires further development and evaluation of the medical-opinion evidence.
What happened
In Fields v. Commissioner of Social Security, the court received no objections to a magistrate judge’s recommended decision and reviewed it for clear error, meaning an obvious mistake.
The court found no clear error and adopted the recommendation in full. It denied the Commissioner’s motion for judgment on the pleadings and sent the matter back to the administrative law judge.
Judge Analisa Torres directed the administrative law judge to seek clarification from Fields’s treating physicians about her functional limitations from October 15, 2013, through December 31, 2018, and then evaluate their opinions under the treating-physician rule.
The detailed version
- Fields v. Commissioner of Social Security · No. 1:19-cv-01423
- Analisa Torres
- June 30, 2020
Background
The court considered a Report and Recommendation issued by Magistrate Judge James L. Cott. No party objected to the recommendation. The court therefore reviewed it for clear error and found none.
Ruling
The court adopted the Report and Recommendation in its entirety. It denied the Commissioner’s motion for judgment on the pleadings and remanded the matter to the administrative law judge under sentence four of 42 U.S.C. § 405(g). A sentence-four remand sends the Social Security case back to the agency for further proceedings after the court rules on the agency’s decision.
Instructions on Remand
The administrative law judge should develop the record by contacting Fields’s treating physicians, Drs. Simons and Guy, and requesting reports clarifying their opinions about the limitations caused by Fields’s impairments during the period from October 15, 2013, through December 31, 2018. After obtaining that clarification, the administrative law judge should evaluate the physicians’ opinions under the treating-physician rule, including discussing any appropriate reasons for giving those opinions less than controlling weight.
Case Status
The Clerk of Court was directed to terminate the motion at ECF No. 12 and close the case. The chambers of Judge Analisa Torres was directed to mail a copy of the order to Fields, who was proceeding without a lawyer.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.