Baker v. Commissioner of Social Security
- John Cronan
- 1:20-cv-08523
- U.S. District Court · Southern District of New York
- 3
Baker v. Commissioner of Social Security: Judge Cronan remanded Baker’s benefits case for further review after finding the ALJ mishandled medical and symptom evidence.
Raleigh Poole Baker and the Commissioner of Social Security; the case returns to the agency for a new hearing and decision.
What happened
In Baker v. Commissioner of Social Security, Raleigh Poole Baker challenged the denial of his application for Social Security Disability Insurance benefits after an administrative law judge found that he was not disabled.
A magistrate judge recommended granting Baker’s request for judgment and denying the Commissioner’s request. The recommendation found that the administrative law judge did not properly evaluate a doctor’s opinion or Baker’s statements about his symptoms.
Judge John P. Cronan adopted the recommendation in full and remanded the case to the Commissioner for further administrative review, including a new hearing and decision.
The detailed version
- Baker v. Commissioner of Social Security · No. 1:20-cv-08523
- John Cronan
- Sept. 26, 2022
Background
Raleigh Poole Baker applied for Social Security Disability Insurance benefits on December 27, 2017. After the application was denied, Baker appeared at a hearing before an administrative law judge (ALJ). The ALJ decided that Baker was not disabled and was not entitled to benefits. The Social Security Appeals Council denied review, making the ALJ’s decision the Commissioner’s final decision.
Baker then asked the district court to review the denial under 42 U.S.C. § 405(g). The parties filed a joint stipulation that the magistrate judge, Ona T. Wang, treated as competing requests for judgment based on the pleadings and the administrative record.
Report and Recommendation
Judge Wang recommended granting Baker’s motion and denying the Commissioner’s motion. She concluded that the ALJ had not properly evaluated the opinion of Baker’s doctor, Dr. Sami Saba, under the regulatory factors concerning whether the opinion was supported and consistent with the evidence. She also concluded that the ALJ had not properly evaluated Baker’s statements about his symptoms.
The parties did not file objections to the recommendation within the required fourteen-day period. The court stated that the parties therefore waived their right to object or obtain appellate review of the recommendation. Despite that waiver, the court conducted its own review of the recommendation.
Ruling
The court found the recommendation well reasoned and adopted it in its entirety. The case was remanded to the Commissioner for further administrative review, including, but not limited to, a new hearing and a new decision about Baker’s entitlement to Social Security Disability Insurance benefits. The court directed the Clerk of Court to enter judgment remanding the case for further proceedings and to close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.