Vigoureux v. Commissioner of Social Security
- George Daniels
- 1:19-cv-07981
- U.S. District Court · Southern District of New York
- 2
In Vigoureux v. Commissioner, Judge Daniels granted the Commissioner’s motion and left the denial of disability insurance benefits in place.
The ruling affected Jeannette Marie Vigoureux’s request for judicial review of the denial of her disability insurance benefits and left that denial in place.
What happened
Jeannette Marie Vigoureux asked the court to review an administrative law judge’s decision denying her disability insurance benefits. The Commissioner of Social Security asked for judgment on the pleadings.
Magistrate Judge Kevin Nathaniel Fox recommended granting the Commissioner’s motion. He concluded that the administrative law judge properly considered Vigoureux’s physical and mental impairments and that the decision was supported by substantial evidence. No party objected to the recommendation.
Judge George B. Daniels reviewed the recommendation for clear error, found none, adopted it, and granted the Commissioner’s motion for judgment on the pleadings. The court therefore left the denial of disability insurance benefits in place.
The detailed version
- Vigoureux v. Commissioner of Social Security · No. 1:19-cv-07981
- George Daniels
- July 8, 2020
Background
Jeannette Marie Vigoureux brought this action under the Social Security Act seeking review of an administrative law judge’s decision denying her disability insurance benefits. The Commissioner of Social Security moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), which permits judgment based on the parties’ pleadings when the material facts are not disputed.
Report and Recommendation
Magistrate Judge Kevin Nathaniel Fox recommended granting the Commissioner’s motion. He concluded that the administrative law judge had considered both Vigoureux’s physical and mental impairments and had properly evaluated their severity in light of the medical evidence. The magistrate judge also determined that the administrative law judge’s conclusion—that Vigoureux did not have an impairment or combination of impairments significantly limiting her ability to perform basic work activities—was supported by substantial evidence.
The parties were advised that failing to object to the report and recommendation could waive objections on appeal. No objections were filed. Because there were no objections, the district court reviewed the recommendation for clear error, meaning an obvious mistake after reviewing the record.
Ruling
Judge George B. Daniels found no error, clear or otherwise, in the magistrate judge’s analysis. The court adopted the report and recommendation and granted the Commissioner’s motion for judgment on the pleadings. The opinion directed the Clerk of Court to close the motion.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.