Acosta Cuevas v. Commissioner of Social Security

Background

Hilda Margarita Acosta Cuevas brought this action under 42 U.S.C. § 405(g), a provision allowing court review of a Social Security decision. She challenged the Commissioner of the Social Security Administration’s denial of her applications for Social Security Disability and Supplemental Security Income benefits.

Report and Recommendation

On January 29, 2021, Magistrate Judge Parker recommended granting Acosta Cuevas’s motion for judgment on the pleadings and denying the Commissioner’s cross-motion. Judgment on the pleadings asks the court to rule based on the existing pleadings and record, without a trial. The recommendation concluded that the Administrative Law Judge’s decision was based on an insufficiently developed record.

The Commissioner objected on two grounds. First, the Commissioner argued that the record was sufficiently developed. Second, the Commissioner argued that the recommendation did not properly evaluate medical opinion evidence under the Social Security Administration’s 2017 regulatory revisions.

Court’s Analysis and Ruling

The court reviewed the Commissioner’s specific objections de novo, meaning it independently considered those issues. It reviewed the remainder of the recommendation for clear error, meaning it looked for a definite mistake. The court agreed with Judge Parker’s analysis and adopted the recommendation, changing one citation from 20 C.F.R. § 404.1512(d) to 20 C.F.R. § 404.1512(b). The court stated that this change was not substantive.

Judge Kimba M. Wood granted Acosta Cuevas’s motion for judgment on the pleadings and denied the Commissioner’s cross-motion. The case was remanded to the Commissioner for additional proceedings in accordance with the recommendation. The clerk was directed to enter judgment and close the case, and any pending motions were declared moot. The opinion does not state the ultimate outcome of Acosta Cuevas’s benefits applications after the remand.