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S.D.N.Y.Substantive rulingFiled June 17, 2021

Escobar v. Saul

Judge
Analisa Torres
Docket
1:20-cv-09653
Court
U.S. District Court · Southern District of New York
Pages
1
Social SecurityCivil Procedure
In one sentence

In Escobar v. Saul, Judge Torres remanded the Social Security case so a different administrative judge could reconsider Escobar’s claims after an Appointments Clause ruling.

Who this affects

Jeannette Escobar, whose Social Security claims will be reconsidered by a different administrative law judge, and the Social Security Administration.

What happened

Jeannette Escobar’s case against Social Security Commissioner Andrew M. Saul was sent back to the Social Security Administration. The judgment relied on the Supreme Court’s decision that a claimant may raise an Appointments Clause challenge for the first time in federal court.

On remand, a different administrative law judge will further evaluate Escobar’s claims. Escobar must be offered an opportunity for a hearing, and the judge must issue a new decision.

Judge Analisa Torres’s court remanded the case under sentence four of the Social Security law. Each side must pay its own attorneys’ fees, costs, and expenses.

The detailed version

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

Case
Escobar v. Saul · No. 1:20-cv-09653
Judge
Analisa Torres
Date
June 17, 2021

Background

Jeannette Escobar sued Andrew M. Saul, the Commissioner of Social Security. The judgment states that the court acted for the reasons given in a Stipulation and Order dated June 16, 2021.

Issue

The case involved an Appointments Clause claim. The judgment cites the Supreme Court’s decision in Carr v. Saul, which held that a claimant does not have to raise an Appointments Clause claim before the Social Security Administration and may instead raise it for the first time in federal court.

Ruling

The court ordered that the action be remanded to the Commissioner of Social Security under sentence four of 42 U.S.C. § 405(g). On remand, the case will be assigned to a different administrative law judge to further evaluate Escobar’s claims. Escobar will be offered an opportunity for a hearing, and the administrative law judge will issue a new decision. Each party will bear its own attorneys’ fees, costs, and expenses.

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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