Santana v. Commissioner of Social Security

Background

Lina Yocasta Santana brought this action under 42 U.S.C. § 205(g), challenging the Commissioner of Social Security’s decision denying her application for Supplemental Security Income. The parties filed cross-motions for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), asking the court to decide the case based on the pleadings and existing record.

The court had referred the case to Magistrate Judge Sarah L. Cave. She issued a report and recommendation advising that Santana’s motion be granted, the Commissioner’s motion be denied, and the case be remanded for further proceedings. The parties were given fourteen days to object, but no objection was filed.

Court’s Analysis

When no timely objection is made to a magistrate judge’s report and recommendation, the district court may adopt the recommendation if the record shows no clear error. The court stated that it reviewed Magistrate Judge Cave’s thorough and well-reasoned recommendation and found no error, clear or otherwise.

Ruling

Judge Ramos adopted the recommendation. Santana’s motion for judgment on the pleadings was granted, the Commissioner’s cross-motion was denied, and the case was remanded for further proceedings. The opinion does not state the specific error in the Commissioner’s decision or otherwise describe what further proceedings must occur.