Reyes v. Commissioner Of Social Security

Background

Frederick Reyes and the Commissioner of Social Security filed cross-motions for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). A motion for judgment on the pleadings asks the court to decide the case based on the pleadings and the existing record, without a trial. Magistrate Judge Gary R. Jones issued a Report and Recommendation dated April 24, 2023.

Judge Jones recommended granting Reyes’s motion and denying the Commissioner’s motion. The recommendation primarily rested on the conclusion that the Administrative Law Judge’s analysis of the evidence concerning Reyes’s migraine headaches was inadequate. Judge Jones also recommended remanding the case to the Social Security Administration for additional administrative proceedings under 42 U.S.C. § 405(g), sentence four.

Court’s Review

The district court explained that it could accept, reject, or modify the magistrate judge’s recommendations. When a party makes a timely, specific objection to a recommendation on a dispositive motion, the district court must independently review the challenged portions. When there is no timely objection, the court may adopt the recommendation unless the record shows clear error.

Neither party objected to Judge Jones’s Report and Recommendation. The district court reviewed the recommendation and the underlying record and found no error, clear or otherwise.

Disposition

The court adopted the Report and Recommendation as its opinion. It granted Reyes’s motion for judgment on the pleadings, denied the Commissioner’s motion for judgment on the pleadings, and remanded the case to the Social Security Administration for further administrative proceedings consistent with the recommendation, under 42 U.S.C. § 405(g), sentence four. The clerk was instructed to enter judgment and close the case.