Eligio v. Commissioner of Social Security

Background

Catalin Yamyleth Eligio sued under § 405(g) of the Social Security Act, which allows federal-court review of certain Social Security decisions. She sought review of an administrative law judge’s August 14, 2019 decision denying her Supplemental Security Income. The administrative law judge found that, during the relevant period, Eligio’s impairments did not make her disabled under the Act.

Report and Recommendation

Magistrate Judge Jennifer E. Willis recommended granting Eligio’s motion for judgment on the pleadings, denying the Commissioner of Social Security’s cross-motion for judgment on the pleadings, and remanding the case for further administrative proceedings. A judgment on the pleadings resolves a case based on the existing pleadings and record rather than after a trial.

Neither Eligio nor the Commissioner objected to the report. The district court therefore reviewed the report for clear error, meaning an obvious mistake apparent from the record. The court found no facial error and adopted the report in its entirety. The opinion does not set out the report’s specific explanation for why remand was required.

Ruling

The court granted Eligio’s motion for judgment on the pleadings, denied the Commissioner’s cross-motion for judgment on the pleadings, and remanded the case for further administrative proceedings. The Clerk of Court was directed to terminate the pending motions and close the case. The court expressly stated that it was not resolving Eligio’s requests for other relief, including attorney’s fees or Supplemental Security Income benefits. The report stated that failure to object within fourteen days would waive objections and preclude appellate review, and the court stated that the parties’ failure to object operated as a waiver of appellate review.