Byrd v. Saul

Background

Craig M. Byrd sought judicial review of an administrative law judge’s determination that he was ineligible for supplemental security income and disability insurance benefits. Byrd moved for judgment on the pleadings, and the Commissioner of Social Security cross-moved for judgment on the pleadings.

Magistrate Judge Sarah L. Cave recommended that Byrd’s motion be denied and that the Commissioner’s motion be granted. The recommendation stated that the administrative law judge had considered the totality of the evidence in determining Byrd’s residual functional capacity—the most he could still do despite his limitations—and that the record supported the administrative law judge’s determination.

Court’s Review

Neither party objected to the report and recommendation. Because no timely objection was filed, the district court reviewed the report for clear error, meaning an obvious mistake on the face of the record. The court found no such error and fully adopted the report.

Disposition

The court adopted the report and recommendation, denied Byrd’s motion for judgment on the pleadings, and granted the Commissioner’s motion for judgment on the pleadings. The Clerk of Court was directed to enter judgment accordingly and close the case. The order also directed substitution of Kilolo Kijakazi, the Acting Commissioner of Social Security, for Andrew Saul in the caption.