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S.D.N.Y.Substantive rulingFiled Oct. 14, 2020

Couvertier v. Social Security

Judge
Sarah Netburn
Docket
1:19-cv-08533
Court
U.S. District Court · Southern District of New York
Pages
1
Social SecurityCivil Procedure
In one sentence

In Couvertier v. Saul, Judge Netburn ordered further Social Security proceedings, affirmed disability after April 4, 2018, and rejected an immediate benefits award.

Who this affects

Blanca I. Couvertier and the Commissioner of Social Security; the remand requires further evaluation of Couvertier’s disability claim for the period before April 4, 2018.

What happened

In Blanca I. Couvertier v. Andrew Saul, the court reviewed the Social Security disability determination and the parties’ requests for relief.

The court granted the Commissioner’s motion to remand. It also granted in part and denied in part a motion seeking judgment on the pleadings and a remand solely to award benefits. The court found that the record did not require only one result, so an immediate benefits award was not appropriate.

Judge Sarah Netburn’s court remanded the matter for further proceedings. The Commissioner must affirm the finding that Couvertier became disabled on April 4, 2018, while the period before that date must be reconsidered, including medical opinions, residual functional capacity, and, if needed, testimony from a vocational expert.

The detailed version

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

Case
Couvertier v. Social Security · No. 1:19-cv-08533
Judge
Sarah Netburn
Date
Oct. 14, 2020

Background

Blanca I. Couvertier challenged the Commissioner of Social Security’s disability determination. The judgment states that the Commissioner had found that Couvertier became disabled beginning April 4, 2018.

Rulings

The court granted the Commissioner’s motion for remand. It also granted in part and denied in part a motion for judgment on the pleadings and for remand solely to obtain an award of benefits. The opinion explains that the record “does not compel but one conclusion,” so an immediate award of benefits was not appropriate.

The court remanded the case for further proceedings under the fourth sentence of 42 U.S.C. § 405(g). On remand, the Commissioner must affirm the administrative law judge’s finding that Couvertier became disabled beginning April 4, 2018. For the period before April 4, 2018, the Commissioner must direct the administrative law judge to further evaluate Dr. Mahony’s opinion together with the other opinion and medical evidence, reassess Couvertier’s residual functional capacity, and obtain vocational-expert testimony if warranted by the expanded record. The judgment states that the case is closed.

Judge

Judge Sarah Netburn presided over the matter identified in the supplied case information.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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