Jecca v. Commissioner of Social Security
- George Daniels
- 1:20-cv-05598
- U.S. District Court · Southern District of New York
- 6
In Jecca v. Commissioner, Judge Daniels remanded Jecca’s disability-benefits case for further review of new medical evidence.
Jecca’s claim for Disability Insurance Benefits will receive further administrative review by the Administrative Law Judge; the Commissioner’s request for judgment was denied.
What happened
In Jecca v. Commissioner of Social Security, Jecca challenged the denial of her application for Disability Insurance Benefits. Both sides asked the court to rule in their favor based on the existing written record.
The court reviewed a magistrate judge’s recommendation and found no clear error. It agreed that the Appeals Council should have considered medical records Jecca later submitted because the records were relevant, supported good cause for the late submission, and could reasonably have changed the decision.
Judge George B. Daniels adopted the recommendation in full, denied the Commissioner’s motion, granted Jecca’s motion, and remanded the case to the Administrative Law Judge for further proceedings.
The detailed version
- Jecca v. Commissioner of Social Security · No. 1:20-cv-05598
- George Daniels
- Sept. 19, 2022
Background
Jecca brought this action under the Social Security Act, 42 U.S.C. § 405(g), seeking review of the Commissioner of Social Security’s denial of her application for Disability Insurance Benefits. Jecca and the Commissioner each moved for judgment on the pleadings, meaning they asked the court to decide the case based on the existing administrative record and written submissions.
Magistrate Judge Barbara Moses recommended granting Jecca’s motion, denying the Commissioner’s motion, and sending the case back to the Administrative Law Judge (ALJ) for further proceedings. No party objected to the recommendation.
Court’s reasoning
Because there were no objections, the district court reviewed the recommendation for clear error and found none. The court explained that the ALJ had received only a scant medical record and, based on that record, found that Jecca did not have any severe impairments. The Social Security Agency had offered to help Jecca obtain medical records, but she declined the offers and tried to obtain and submit the records independently.
Jecca later provided the Appeals Council with fuller medical records. The court agreed with Magistrate Judge Moses that the Appeals Council incorrectly rejected this additional evidence. The records were relevant to the period covered by the ALJ’s decision, and Jecca had good cause for not providing them earlier because the records either went astray in the mail or were mishandled by Social Security staff. The court also agreed that the evidence created a reasonable probability that the ALJ could have reached a different conclusion about whether Jecca had a severe disability. Therefore, the Appeals Council’s failure to consider the evidence was not harmless.
Disposition
Judge Daniels adopted the Report and Recommendation in full. The court denied the Commissioner’s motion for judgment on the pleadings, granted Jecca’s motion for judgment on the pleadings, and remanded the case to the ALJ for further proceedings in accordance with the order and the report. The opinion did not award benefits or decide that Jecca was disabled.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.