Miranda L. v. Commissioner of Social Security
- Jones
- 1:23-cv-00869
- U.S. District Court · Southern District of New York
- 5
In Miranda L. v. Commissioner of Social Security, Judge Jones denied the Commissioner’s request to change the remand judgment.
Miranda L. and the Commissioner of Social Security; the case continues with the previously ordered administrative remand.
What happened
Miranda L. v. Commissioner of Social Security concerns Miranda L.’s request for judicial review after the Commissioner denied her application for Supplemental Security Income. The court had previously ruled for Miranda L. and ordered further administrative proceedings.
The Commissioner asked the court to change that judgment, arguing that the court should not have directed the administrative law judge to obtain an opinion from Miranda L.’s treating psychiatrist. The court explained that the duty to develop a complete record still applies under the newer regulations and that the psychiatrist’s opinion was needed to decide whether Miranda L. was disabled.
Judge Gary R. Jones denied the Commissioner’s motion to alter or amend the judgment. The earlier remand therefore remained in place.
The detailed version
- Miranda L. v. Commissioner of Social Security · No. 1:23-cv-00869
- Jones
- Apr. 3, 2024
Background
Miranda L. applied for Supplemental Security Income in August 2019. The Commissioner of Social Security denied the application, and Miranda L., represented by counsel, sought judicial review under 42 U.S.C. §§ 405(g) and 1383(c)(3).
On January 30, 2024, the court granted Miranda L. judgment on the pleadings and ordered a remand for further administrative proceedings. A remand sends the matter back to the agency for additional proceedings. The court had found that the administrative law judge did not adequately develop the record. Among other things, the record contained a letter from Dr. Dusan Pekovic, a psychiatrist who stated that he had treated Miranda L. for five and a half years and diagnosed bipolar disorder, but the record did not contain his assessment of her functional limitations. The court also noted that two other mental-health professionals had assessed greater work-related limitations than the administrative law judge did.
Motion to Alter or Amend
The Commissioner moved under Rule 59(e) of the Federal Rules of Civil Procedure to alter or amend the judgment. The Commissioner did not challenge the remand itself. Instead, the Commissioner objected to the court’s instruction that the administrative law judge obtain an opinion from Miranda L.’s treating psychiatrist, arguing that the instruction was inconsistent with newer regulations governing medical-opinion evidence and improperly limited the administrative law judge’s discretion.
The court applied the strict standard for reconsideration. It explained that such relief generally requires an intervening change in controlling law, new evidence, or a need to correct clear legal error or prevent manifest injustice. The Commissioner presented no new evidence and did not claim that the law had changed.
Court’s Analysis
The court held that the duty to develop the record continues to apply under the newer regulations. That duty can include contacting treating providers again when necessary to give the claimant a full and fair hearing based on a properly developed record. The court concluded that, for the reasons given in its earlier decision, obtaining an opinion from Dr. Pekovic was necessary to determine whether Miranda L. was disabled under the Social Security Act.
Disposition
Judge Gary R. Jones denied the Commissioner’s Motion to Alter or Amend the Judgment. The court’s earlier judgment granting Miranda L. judgment on the pleadings and directing a remand remained in effect.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.