Candelario v. O'Malley
- Jesse Furman
- 1:23-cv-07144
- U.S. District Court · Southern District of New York
- 2
Candelario v. O’Malley: Judge Furman remanded the Social Security case after finding the administrative law judge improperly rejected medical evidence and testimony.
Michelle Candelario and the Commissioner of Social Security; the case was sent back to the Commissioner for further proceedings.
What happened
In Candelario v. O’Malley, a magistrate judge recommended sending Michelle Candelario’s Social Security case back to the Commissioner for further proceedings. The recommendation was based on errors by the administrative law judge.
Neither party filed objections to the recommendation or asked for more time to do so. The court therefore found that the parties waived their rights to object and to seek appellate review of the recommendation.
Judge Jesse Furman reviewed the record and adopted the recommendation in full. He ruled that the administrative law judge improperly discredited medical evidence and Candelario’s testimony, and remanded the case to the Commissioner for further proceedings.
The detailed version
- Candelario v. O'Malley · No. 1:23-cv-07144
- Jesse Furman
- Apr. 18, 2024
Background
Michelle Candelario’s Social Security action was referred to a magistrate judge. On April 3, 2024, Magistrate Judge Jones issued a Report and Recommendation advising that the case be remanded to the Commissioner of Social Security for further proceedings under Section 405(g) of the Social Security Act.
Review of the Recommendation
The district court explained that it may accept, reject, or modify a magistrate judge’s recommendation. When a party properly objects, the district court must independently review the challenged portions. When no timely objection is made, the court generally reviews the recommendation for clear error, meaning an obvious mistake in the record or legal analysis. That limited standard also applies to conclusory or general objections.
The Report and Recommendation gave the parties fourteen days to object and warned that failing to object would waive the right to object. No objections or requests for an extension were filed. The court therefore concluded that the parties waived their rights to object to the recommendation and to obtain appellate review.
Ruling
Despite the waiver, the court reviewed the parties’ briefs, the administrative record, and the Report and Recommendation. It found the recommendation well reasoned and supported by the facts and law. The court agreed that the administrative law judge improperly discredited medical evidence and Michelle Candelario’s testimony.
The court adopted the Report and Recommendation in its entirety and remanded the case to the Commissioner for further proceedings under Section 405(g). The Clerk of Court was directed to close the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.