Muniz v. Commissioner of Social Security
- Andrew Krause
- 7:19-cv-01103
- U.S. District Court · Southern District of New York
- 1
In Muniz v. Commissioner, Judge Krause remanded the Social Security case for a new review, hearing opportunity, and decision before a different administrative law judge.
The plaintiff’s Social Security claims will receive further evaluation by a different administrative law judge, with an opportunity for a hearing and a new decision by the Commissioner of Social Security.
What happened
In Muniz v. Commissioner of Social Security, the plaintiff challenged the handling of his Social Security claims. The court’s judgment refers to a June 2, 2021 stipulation and order and to the Supreme Court’s decision in Carr v. Saul.
The Supreme Court held that a claimant does not have to raise an Appointments Clause challenge before the Social Security Administration and may raise it for the first time in federal court. The judgment states that this case was remanded on that basis.
The court ordered a sentence-four remand under 42 U.S.C. § 405(g). On remand, a different administrative law judge must further evaluate the plaintiff’s claims, offer the plaintiff a hearing, and issue a new decision. Judge Andrew Krause is identified in the provided case information.
The detailed version
- Muniz v. Commissioner of Social Security · No. 7:19-cv-01103
- Andrew Krause
- June 2, 2021
Background
The plaintiff, identified in the caption as BRANDONGILMUNIZ, brought this Social Security case against Andrew M. Saul, the Commissioner of Social Security. The judgment states that the action was resolved through a stipulation and order dated June 2, 2021.
Reason for Remand
The judgment relied on the Supreme Court’s decision in Carr v. Saul, 141 S. Ct. 1352 (2021). Carr held that a Social Security claimant does not have to raise an Appointments Clause challenge before the Social Security Administration and may instead raise that challenge for the first time in federal court.
Ruling and Effect
The court ordered that the action be remanded to the Commissioner under sentence four of 42 U.S.C. § 405(g). The remand requires the case to be assigned to a different administrative law judge, who must further evaluate the plaintiff’s claims, offer the plaintiff an opportunity for a hearing, and issue a new decision. The judgment does not state the result of the plaintiff’s underlying Social Security claims.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.