Garcia v. Commissioner of Social Security
- Stewart Aaron
- 1:21-cv-01230
- U.S. District Court · Southern District of New York
- 5
Garcia v. Commissioner of Social Security: Judge Aaron granted in part and denied in part a motion clarifying that only Garcia’s SSI claim was remanded.
Rebecca Maria Garcia’s SSI claim remains the subject of the remand for further proceedings. The court clarified that the remand did not extend to her period-of-disability and disability-insurance claim.
What happened
Rebecca Maria Garcia challenged the Social Security Administration’s decision concerning her claims for disability insurance benefits and supplemental security income. In an earlier decision, the court had remanded the SSI claim for further proceedings, while Garcia had not challenged the finding on her disability-insurance claim.
The Commissioner asked the court to amend the judgment to make clear that only the SSI claim was being remanded and that the Commissioner’s decision on the disability-insurance claim should be affirmed. The Commissioner filed the motion under Rule 59(e), which allows a court to alter or amend a recently entered judgment.
In Garcia v. Commissioner of Social Security, Judge Aaron granted in part and denied in part the Commissioner’s motion. The court clarified that its remand was based solely on Garcia’s SSI claim and directed the clerk to enter an amended judgment consistent with that clarification.
The detailed version
- Garcia v. Commissioner of Social Security · No. 1:21-cv-01230
- Stewart Aaron
- Nov. 22, 2022
Background
Rebecca Maria Garcia applied for a period of disability and disability insurance benefits under Title II of the Social Security Act and for supplemental security income under Title XVI. She alleged that her disability began on November 1, 2013. Her date last insured for disability-insurance benefits was December 31, 2014.
An administrative law judge found that Garcia was not disabled. For the Title II claim, the administrative law judge found that Garcia had not established a medically determinable impairment before her date last insured. For the SSI claim, the administrative law judge found at the fourth step of the disability-evaluation process that Garcia could perform her past relevant work. The Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.
In an earlier opinion, the court remanded the case for further proceedings regarding Garcia’s SSI claim. That opinion stated that the record did not contain medical evidence from before Garcia’s date last insured and that Garcia did not challenge the finding concerning her disability-insurance claim. The judgment entered after that opinion stated generally that the case had been remanded for further proceedings before the Social Security Administration.
Motion and Discussion
The Commissioner moved under Federal Rule of Civil Procedure 59(e) to amend the judgment. The requested amendment was intended to state that only Garcia’s SSI claim was remanded and that the Commissioner’s final decision regarding the period-of-disability and disability-insurance claim was affirmed.
The court explained that its earlier opinion had expressly noted that Garcia did not challenge the administrative law judge’s finding on the disability-insurance claim and that the remand was based on the SSI claim. The court therefore clarified that its decision to remand was solely based on the SSI claim.
Disposition
The court granted in part and denied in part the Commissioner’s motion. It clarified that the remand applied solely to Garcia’s SSI claim and directed the clerk to enter an amended judgment consistent with that clarification. The opinion does not independently conduct a new merits review of Garcia’s disability-insurance claim.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.