Galindez v. Commissioner of Social Security
- Vyskocil
- 1:19-cv-04548
- U.S. District Court · Southern District of New York
- 3
In Galindez v. Commissioner of Social Security, Judge Vyskocil vacated the benefits denial and remanded for further proceedings.
Edwin Galindez’s claim for supplemental security income benefits was returned to the Social Security Administration for further proceedings; the Commissioner’s denial was vacated.
What happened
Edwin Galindez asked the court to review the Commissioner of Social Security’s denial of his application for supplemental security income benefits. The case was referred to Magistrate Judge Wang, who recommended sending it back for further proceedings.
The recommendation identified several problems with the administrative law judge’s decision, including failure to consider some medical treatment, failure to adequately explain the limited weight given to treating medical sources, failure to develop the record, and failure to evaluate Galindez’s complaints about vertigo and anxiety.
Judge Mary Kay Vyskocil adopted the recommendation in full. She granted Galindez’s motion for judgment on the pleadings insofar as the case was remanded for further proceedings, denied the Commissioner’s motion, vacated the benefits denial, and remanded the case to the Social Security Administration.
The detailed version
- Galindez v. Commissioner of Social Security · No. 1:19-cv-04548
- Vyskocil
- Nov. 9, 2020
Background
Edwin Galindez sought judicial review of the Commissioner of Social Security’s decision denying his application for supplemental security income benefits. Galindez moved for judgment on the pleadings, a request for judgment based on the existing court filings and administrative record. The Commissioner filed a cross-motion for the same relief.
The case had been referred to Magistrate Judge Wang for a report and recommendation. Judge Wang recommended granting Galindez’s motion insofar as the case should be remanded for further proceedings and denying the Commissioner’s motion. Neither party filed an objection within the allowed period.
Reasons for Remand
Judge Wang found that the administrative law judge did not adequately address or consider the treatment Galindez received from Dr. Rosa and Dr. Chambliss. The administrative law judge also did not provide adequate reasons for giving little weight to the opinions of treating sources Dr. Nwokeji and N.P. Cornay, and did not clarify those opinions as required by the cited regulation. The report concluded that these problems meant the administrative law judge did not correctly apply the treating-source rule and could not properly determine Galindez’s residual functional capacity, meaning his ability to work despite his limitations.
The report also found that the administrative law judge did not evaluate Galindez’s complaints about vertigo and anxiety. Judge Vyskocil reviewed the report and the administrative record and found no error, clear or otherwise, in Judge Wang’s analysis.
Ruling
Judge Vyskocil adopted Judge Wang’s report and recommendation in its entirety. Galindez’s motion for judgment on the pleadings was granted insofar as this case was remanded for further proceedings. The Commissioner’s motion for judgment on the pleadings was denied. The court vacated the Commissioner’s decision denying supplemental security income benefits and remanded the case to the Social Security Administration for further proceedings consistent with the report and recommendation. The court directed the clerk to terminate the motions and close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.