Boland v. Commissioner of Social Security
- Edgardo Ramos
- 1:20-cv-07312
- U.S. District Court · Southern District of New York
- 3
In Boland v. Commissioner of Social Security, Judge Ramos denied Boland’s motion, granted the Commissioner’s motion, and dismissed the case.
Daniel M. Boland did not obtain disability insurance benefits or Supplemental Security Income through this case. The Commissioner of Social Security prevailed, and the case was dismissed.
What happened
In Boland v. Commissioner of Social Security, Daniel M. Boland asked the court to review the denial of his applications for disability insurance benefits and Supplemental Security Income. A magistrate judge recommended ruling for the Commissioner because the administrative law judge’s decision was supported by substantial evidence.
Boland alleged that traumatic brain injury, epilepsy, blindness in his left eye, and cognitive impairment entitled him to benefits. After a hearing, the administrative law judge found that he was not disabled, and the Social Security Administration’s Appeals Council declined to review that decision. The parties then filed competing motions asking for judgment based on the existing court record.
Neither party objected to the magistrate judge’s recommendation. Judge Ramos found no error, adopted the recommendation in full, denied Boland’s motion for judgment on the pleadings, granted the Commissioner’s cross-motion, and dismissed the case. The court also stated that the failure to file written objections precluded appellate review of the decision.
The detailed version
- Boland v. Commissioner of Social Security · No. 1:20-cv-07312
- Edgardo Ramos
- Mar. 31, 2022
Background
Daniel M. Boland sought review under Section 405(g) of the Social Security Act of the Commissioner’s decision denying his applications for disability insurance benefits and Supplemental Security Income. He applied for disability insurance benefits on May 15, 2017, and for Supplemental Security Income on June 17, 2017. He alleged disability based on traumatic brain injury, epilepsy, blindness in his left eye, and cognitive impairment.
Both applications were denied on October 25, 2017. After a hearing at which Boland appeared with counsel and testified, along with testimony from a vocational expert, administrative law judge Sandra R. DiMaggio Wallis found on August 2, 2019, that Boland was not disabled under the Social Security Act. The Appeals Council denied his request for review on July 6, 2020. Boland then filed this case.
Report and Recommendation
The parties filed competing motions for judgment on the pleadings, which asks the court to decide the case based on the existing pleadings and administrative record. The case had been referred to Magistrate Judge Barbara C. Moses. Her amended Report and Recommendation advised granting the Commissioner’s motion and denying Boland’s motion because the administrative law judge’s decision was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate to support the decision.
The parties were given fourteen days to submit written objections. At Boland’s request, the court extended his deadline to March 29, 2022. No objections were filed, and Boland’s counsel confirmed that he did not intend to object.
Ruling
Judge Ramos reviewed the Report and Recommendation and found no error, including no clear error in the portions that could be adopted without a full new review. The court adopted the Report and Recommendation in full.
The court denied Boland’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion. The case was dismissed. The Clerk was directed to terminate the motions, close the case, and enter judgment consistent with the order. The court also stated that the parties’ failure to file written objections precluded appellate review of the decision.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.