Mazza v. Commissioner of Social Security

Background

Liza Loring Mazza brought this action under sections 205(g) and 1631(c)(3) of the Social Security Act, 42 U.S.C. §§ 405(g) and 1383(c)(3), seeking judicial review of the Commissioner of Social Security’s final decision denying her application for disability insurance benefits.

Mazza moved for judgment on the pleadings, which asks the court to decide the case based on the administrative record and the parties’ written submissions. The Commissioner filed a competing motion for judgment on the pleadings.

Magistrate Judge’s Recommendation

Magistrate Judge Jennifer E. Willis issued a Report and Recommendation. She concluded that the administrative law judge failed to account for Mazza’s non-severe mental impairments and therefore failed to consider the combined effect of Mazza’s physical and mental impairments when assessing her residual functional capacity. Residual functional capacity is the most a claimant can do despite her impairments. The magistrate judge determined that the residual-functional-capacity analysis was not supported by substantial evidence and recommended remand.

The recommendation called for granting Mazza’s motion and denying the Commissioner’s motion. Neither party filed an objection or requested additional time to object.

District Court’s Ruling

Judge Vernon S. Broderick reviewed the recommendation for clear error, meaning an obvious mistake apparent from the record. He found none and adopted the Report and Recommendation in its entirety.

The court granted Mazza’s motion for judgment on the pleadings, denied the Commissioner’s motion for judgment on the pleadings, and remanded the case to the Commissioner under sentence four of 42 U.S.C. § 405(g). The Clerk was directed to enter judgment remanding the case, terminate any open motions, and close the case.