Iroakazi v. Commissioner of Social Security

Background

The court considered Magistrate Judge Andrew E. Krause’s February 4, 2022 Report and Recommendation concerning the parties’ cross-motions for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The recommendation concluded that the administrative law judge committed legal errors by failing to properly apply the treating physician rule to the opinions of Iroakazi’s treating physician, Dr. Joseph Squitieri, and by assigning significant weight to the opinion of expert witness Dr. Edward N. Halperin. It recommended granting Iroakazi’s motion, denying the defendant’s motion, and remanding the case to the Social Security Administration for further administrative proceedings.

The opinion states that Kilolo Kijakazi was substituted as the defendant under Federal Rule of Civil Procedure 25(d). Neither party objected to the Report and Recommendation. Because there were no objections, the court reviewed the recommendation and the underlying record for error and found no error, clear or otherwise.

Ruling

Judge Vincent L. Briccetti adopted the Report and Recommendation as the court’s opinion. Iroakazi’s motion for judgment on the pleadings was granted, and the defendant’s motion for judgment on the pleadings was denied. The case was remanded to the Social Security Administration for further administrative proceedings consistent with the recommendation under 42 U.S.C. § 405(g), sentence four. The clerk was instructed to enter judgment and close the case.