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S.D.N.Y.Substantive rulingFiled Feb. 11, 2022

Williams v. Commissioner of Social Security

Judge
Vernon Broderick
Docket
1:20-cv-05954
Court
U.S. District Court · Southern District of New York
Pages
3
Social SecurityCivil Procedure
In one sentence

In Williams v. Commissioner of Social Security, Judge Broderick granted the Commissioner’s motion, denied Williams’s motion, and closed the case.

Who this affects

Pamela C. Williams, whose challenge to the dismissal of her Social Security Disability benefits hearing request was rejected, and the Commissioner of Social Security, whose motion was granted.

What happened

Pamela C. Williams challenged the Social Security Administration’s handling of her application for disability benefits. She had not attended a scheduled hearing, and the administrative law judge found that she lacked a good reason for missing it and dismissed her request.

The Commissioner asked the court to uphold the administrative law judge’s decision, arguing that the finding about the lack of good cause was supported by the evidence. Williams asked the court to order a hearing on the merits or allow her to provide evidence about whether she had good cause for missing the hearing.

Neither side objected to the magistrate judge’s recommendation that the Commissioner’s motion be granted and Williams’s motion be denied. Judge Broderick found no clear error, adopted the recommendation in full, directed entry of judgment, and closed the case.

The detailed version

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

Case
Williams v. Commissioner of Social Security · No. 1:20-cv-05954
Judge
Vernon Broderick
Date
Feb. 11, 2022

Background

Pamela C. Williams brought this action under Section 205(g) of the Social Security Act, 42 U.S.C. § 405(g), seeking review of the Commissioner of Social Security’s final decision concerning her application for Social Security Disability benefits. Williams had requested a hearing before an administrative law judge. The hearing was scheduled for July 19, 2019, but Williams did not attend. The administrative law judge found that Williams had not shown good cause for failing to appear and issued a notice dismissing the matter on July 29, 2019.

Williams asked the Appeals Council to review the dismissal. The Appeals Council denied that request on June 15, 2020. Williams then appealed to the district court.

Motions and Report and Recommendation

The Commissioner moved for judgment on the pleadings, a decision based on the parties’ written submissions, arguing that substantial evidence supported the administrative law judge’s finding that Williams had not shown good cause for missing the hearing. Williams also moved for judgment on the pleadings, arguing that the court should remand the matter for a hearing on the merits or at least allow her to submit evidence concerning whether she had good cause for not appearing.

Magistrate Judge Sarah L. Cave issued a Report and Recommendation recommending that the Commissioner’s motion for judgment on the pleadings be granted and Williams’s motion for judgment on the pleadings be denied.

Court’s Review and Ruling

Neither party objected to the Report and Recommendation. Because there were no timely objections, Judge Vernon S. Broderick reviewed the recommendation for clear error, meaning an obvious mistake apparent from the record. He found no clear error and adopted the Report and Recommendation in its entirety.

The court granted the Commissioner’s motion for judgment on the pleadings and denied Williams’s motion for judgment on the pleadings. The Clerk’s Office was directed to terminate the open motions, enter judgment in accordance with the order, and close the case.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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