Arndt v. Commissioner of Social Secuirty
- Nelson Roman
- 7:19-cv-03174
- U.S. District Court · Southern District of New York
- 4
In Arndt v. Commissioner of Social Security, Judge Roman denied the Commissioner’s motion and remanded Arndt’s disability-benefits case for further proceedings.
Janice Arndt’s disability-benefits claim returns to the Social Security Administration for further proceedings; the Commissioner’s request to uphold the denial was denied.
What happened
Janice Arndt challenged the Social Security Administration’s decision denying her application for Supplemental Security Income disability benefits. She alleged disabilities including spinal and joint problems and mental-health conditions.
The Commissioner asked the court to uphold the administrative decision. A magistrate judge recommended denying that request and sending the case back to the agency because the administrative law judge had completely ignored opinions from agency medical examiners about Arndt’s psychological limitations.
In Arndt v. Commissioner of Social Security, Judge Nelson S. Roman adopted the recommendation in full, denied the Commissioner’s motion for judgment on the pleadings, and remanded the matter to the Social Security Administration for further proceedings.
The detailed version
- Arndt v. Commissioner of Social Secuirty · No. 7:19-cv-03174
- Nelson Roman
- Oct. 16, 2020
Background
Janice Arndt, who was proceeding without a lawyer in this federal action, challenged the Commissioner of Social Security’s denial of her application for Supplemental Security Income disability benefits under the Social Security Act. Arndt originally alleged that she was disabled because of, among other conditions, herniated discs, a right knee replacement, a left hip tear, and mental-health-related illness.
An administrative law judge held a hearing on November 29, 2017, at which Arndt was represented by counsel and testified. The administrative law judge determined on February 23, 2018, that Arndt was not disabled. The Commissioner later denied Arndt’s request for administrative review. Arndt then filed this action under 42 U.S.C. §§ 405(g) and 1383(c).
Report and Recommendation
The case was referred to Magistrate Judge Paul E. Davison, who considered the Commissioner’s motion for judgment on the pleadings. That motion asked the court to rule for the Commissioner and deny Arndt’s claim for benefits. Judge Davison recommended denying the motion and remanding the case to the Social Security Administration for further proceedings.
The report explained that, although the administrative law judge found limitations in Arndt’s residual functional capacity, the judge “completely ignored” agency consultative examiners’ opinions that Arndt was moderately limited in maintaining a regular schedule and attendance and in completing a normal workday or workweek without interruptions from ongoing psychological symptoms.
District Court’s Review and Ruling
The parties did not object to the report and recommendation or request more time to do so. The court stated that they therefore waived their right to object and to obtain appellate review. Even so, Judge Nelson S. Roman reviewed the Commissioner’s motion and the report and found no clear error.
Judge Roman adopted the report and recommendation in its entirety. The court denied the Commissioner’s motion for judgment on the pleadings and remanded the matter to the Social Security Administration for further proceedings consistent with the report and recommendation. The order did not award benefits or make a final determination that Arndt was disabled.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.