Taveras v. Commissioner of Social Security
- Katharine Parker
- 1:22-cv-10825
- U.S. District Court · Southern District of New York
- 2
In Taveras v. Commissioner, Judge Parker declined to endorse the proposed stipulation and order, extended a filing deadline, and invited further briefing.
Elvira Taveras and the Commissioner of Social Security; the order also affected the parties’ deadlines and briefing about changing or vacating the court’s earlier order.
What happened
In Taveras v. Commissioner of Social Security, the court had previously granted Elvira Taveras’s request for judgment on the pleadings and sent the case back for reconsideration by an Administrative Law Judge. Taveras then asked the court to change its judgment, arguing that the case should have been sent back with instructions to pay benefits.
The parties later submitted a proposed joint stipulation and order that would cancel the earlier decision and require a fully favorable decision with payment of benefits to Taveras. The Commissioner opposed the request to change the judgment while supporting the proposed cancellation and benefits award.
The court declined to endorse the proposed stipulation and order at that time. Judge Parker extended the Commissioner’s deadline to oppose Taveras’s motion by one week, until May 9, 2024, and allowed the parties to submit a joint letter addressing the legal standard for canceling the earlier order.
The detailed version
- Taveras v. Commissioner of Social Security · No. 1:22-cv-10825
- Katharine Parker
- Apr. 17, 2024
Background
On February 17, 2024, the court granted Elvira Taveras’s motion for judgment on the pleadings and remanded the case to the Administrative Law Judge (ALJ) for reconsideration. On March 19, 2024, Taveras moved to alter or amend the judgment, arguing that it was legal error to remand the case without instructions to pay benefits.
The parties then submitted a proposed joint stipulation and order. The proposal would vacate, or cancel, the court’s earlier opinion and order and enter a judgment remanding the case for a fully favorable decision with payment of benefits to Taveras.
Court’s Analysis
The court found the proposed stipulation and order deficient because it did not address the standards for changing or vacating the court’s earlier order. The court explained that reconsideration is an extraordinary remedy used sparingly, and that changing a judgment may require correcting an error or preventing a clear injustice. It also explained that vacating an order requires a showing that the relief is justified by exceptional circumstances. The parties’ agreement was relevant but, by itself, was not enough.
The court also expressed concern that the Commissioner’s opposition to Taveras’s motion to amend, combined with support for vacating the earlier ruling and ordering a full award of benefits, could suggest an attempt by an institutional litigant to influence the development of the law by settling an unfavorable ruling.
Order
The court declined to endorse the proposed stipulation and order at that time. It extended the Commissioner’s deadline to oppose the motion to amend by one week, to May 9, 2024. The court also permitted the parties to file a joint letter of no more than six pages by that date addressing the standard for vacatur in support of their proposed order. This order did not itself grant the requested payment of benefits or vacate the earlier opinion and order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.