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S.D.N.Y.Substantive rulingFiled Sept. 28, 2022

Vargas v. Saul

Judge
Vyskocil
Docket
1:21-cv-04676
Court
U.S. District Court · Southern District of New York
Pages
2
Social SecurityCivil Procedure
In one sentence

In Vargas v. Saul, Judge Vyskocil denied Vargas’s motion and granted the Commissioner’s motion, upholding the Social Security disability decision.

Who this affects

Jinelsie Vargas, whose claim for Disability Insurance Benefits and Supplemental Security Income remained denied, and the Commissioner of Social Security.

What happened

In Vargas v. Saul, Jinelsie Vargas asked the district court to overturn the Social Security Administration’s decision denying her Disability Insurance Benefits and Supplemental Security Income. She requested a finding that she was disabled or, alternatively, further administrative proceedings.

A magistrate judge recommended denying Vargas’s motion and granting the Commissioner’s motion to affirm the decision. No party objected. The district court reviewed the recommendation for clear error and agreed that the administrative law judge did not improperly rely on Vargas’s alleged disability-onset date, did not improperly apply the treating-physician rule, and supported the decision with substantial evidence.

Judge Mary Kay Vyskocil adopted the recommendation in full. She denied Vargas’s motion, granted the Commissioner’s motion, and directed the Clerk of Court to close the case.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Vargas v. Saul · No. 1:21-cv-04676
Judge
Vyskocil
Date
Sept. 28, 2022

Background

Jinelsie Vargas, represented by counsel, sued the Commissioner of Social Security under 42 U.S.C. § 405(g), seeking review of the decision that she was not entitled to Disability Insurance Benefits or Supplemental Security Income. Vargas moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). She asked the court to vacate the Commissioner’s decision and either direct a finding of disability and calculation of benefits or order further administrative proceedings. The Commissioner filed a cross-motion for judgment on the pleadings asking the court to affirm the decision.

Report and Recommendation

The court had referred the case to Magistrate Judge Netburn. She recommended denying Vargas’s motion and granting the Commissioner’s motion. Neither party filed timely objections, and the court received no untimely objections. Without objections, the district court reviewed the recommendation for clear error.

Court’s Analysis

The district court found the Report and Recommendation well-reasoned and supported by the facts and law. It agreed that the administrative law judge did not err by relying on Vargas’s statement, made through counsel, concerning her alleged disability-onset date. The court also agreed that the substance of the treating-physician rule was not improperly disregarded and that the administrative law judge’s analysis was supported by substantial evidence.

Disposition

The court adopted the Report and Recommendation in its entirety. Vargas’s motion was DENIED. The Commissioner’s motion was GRANTED. The Clerk of Court was respectfully requested to close the case.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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