Peralta Bonifacio v. Commissioner of Social Security
- George Daniels
- 1:20-cv-00972
- U.S. District Court · Southern District of New York
- 4
In Peralta Bonifacio v. Kijakazi, Judge Daniels upheld the disability-benefits denial, finding substantial evidence supported the administrative law judge’s decision.
The ruling affected Maribel Peralta Bonifacio’s challenge to the denial of disability insurance benefits and supplemental security income, and it granted the Commissioner’s request for judgment on the pleadings.
What happened
Maribel Peralta Bonifacio v. Kilolo Kijakazi, Commissioner of Social Security concerned a challenge to an administrative law judge’s denial of disability insurance benefits and supplemental security income. The court reviewed the decision under the Social Security Act.
Peralta Bonifacio argued that the administrative law judge incorrectly assessed her work-related abilities and did not properly evaluate her reports about her physical and mental conditions. A magistrate judge recommended denying her motion and granting the Commissioner’s motion for judgment based on the pleadings.
Because neither side objected, Judge George B. Daniels reviewed the recommendation for clear error and adopted it in full. The court denied Peralta Bonifacio’s motion and granted the Commissioner’s cross-motion, concluding that substantial evidence supported the administrative law judge’s decision.
The detailed version
- Peralta Bonifacio v. Commissioner of Social Security · No. 1:20-cv-00972
- George Daniels
- Sept. 27, 2021
Background
Maribel Peralta Bonifacio brought this action under the Social Security Act, 42 U.S.C. § 405(g), seeking review of an administrative law judge’s decision denying her disability insurance benefits and supplemental security income. Both parties moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), which allows a court to decide a case based on the pleadings when the moving party is entitled to judgment as a matter of law.
Magistrate Judge Ona T. Wang recommended denying Peralta Bonifacio’s motion and granting the Commissioner’s cross-motion. Neither party filed objections. The district court therefore reviewed the recommendation for clear error, meaning it would reject a finding only if it had a firm conviction that a mistake had been made.
Arguments and Analysis
The administrative law judge found that Peralta Bonifacio had the residual functional capacity to perform light work. Light work generally involves lifting up to 20 pounds at a time, frequently lifting or carrying objects weighing up to 10 pounds, and substantial walking or standing, or sitting with some pushing and pulling of controls.
Peralta Bonifacio argued that the administrative law judge improperly assessed her residual functional capacity and improperly evaluated her descriptions of her physical and mental symptoms. The court concluded that medical records from her physicians, medical imaging, and a consultative examination supported the finding that she could perform light work. The court also noted that her conditions were improving with treatment and that no physician had made an objective finding restricting her ability to sit, stand, climb, or push, pull, or carry heavy objects.
The court further concluded that the administrative law judge properly considered Peralta Bonifacio’s reported symptoms. Her daily activities and medical records provided substantial evidence that some of her complaints were inconsistent with the overall record. The court found no obvious inconsistency requiring the administrative law judge to obtain additional evidence.
Ruling
Judge George B. Daniels adopted Magistrate Judge Wang’s report in full after finding no clear error. The court held that the Commissioner’s denial of disability insurance benefits and supplemental security income was supported by substantial evidence and that the correct legal standards had been applied.
The court denied Peralta Bonifacio’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion for judgment on the pleadings.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.