Henderson v. Saul
- Proceeding
- district
- Area
- civil
- Panel
- Cynthia Ann Bashant (author)
Analysis
The court reviewed a Magistrate Judge's Report and Recommendation (R&R) in a Social Security disability case where no objections were filed by the parties. The court adopted the R&R in its entirety, granted the plaintiff's motion for summary judgment, denied the defendant's cross-motion, and remanded the case for further administrative proceedings.
| What the court decided | Standard it applied | The model |
|---|---|---|
Adopting the Report and Recommendation in its entirety“Therefore, the Court approves and ADOPTS IN ITS ENTIRETY the R&R.” | de novo | agree with court The court correctly applied the standard for reviewing a Magistrate Judge's R&R. While 28 U.S.C. § 636(b)(1) requires de novo review only for objected-to portions, the court voluntarily conducted a de novo review and found the reasoning sound. The citation to *United States v. Reyna-Tapia* supports the proposition that a district judge is not required to review unobjected-to R&Rs, but the court's choice to do so and find the R&R correct is procedurally sound and legally appropriate. |
Granting Plaintiff's Motion for Summary Judgment“GRANTS Plaintiff's Motion for Summary Judgment (ECF No. 18)” | substantial evidence | agree with court The court adopted the Magistrate Judge's recommendation to grant summary judgment. In Social Security cases, summary judgment is the standard mechanism for reviewing the ALJ's decision. The court cited the correct standard of review (substantial evidence) and the correct authorities (*Andrews v. Shalala*, *Magallenes v. Bowen*). By adopting the R&R, the court effectively found that the ALJ's decision was not supported by substantial evidence or was based on legal error, as recommended by the Magistrate. |
Denying Defendant's Cross-Motion for Summary Judgment“DENIES Defendant's Cross Motion for Summary Judgment (ECF No. 19)” | substantial evidence | agree with court This ruling is the logical counterpart to granting the plaintiff's motion. If the plaintiff's motion to reverse the ALJ's decision is granted, the defendant's motion to affirm must be denied. The court correctly applied the substantial evidence standard in making this determination. |
Remanding the action for further proceedings“The Court REMANDS this action for further proceedings consistent with this Order.” | unclear | agree with court Remand is the standard remedy when a Social Security decision is found to be unsupported by substantial evidence or based on legal error. The court correctly ordered remand under 42 U.S.C. § 405(g). |
The order itself: sound — The order is procedurally sound. The court correctly identified the standard for reviewing a Magistrate Judge's R&R when no objections are filed. Although the court noted it had no obligation to review the R&R de novo, it voluntarily did so and found the reasoning sound. The court correctly cited the relevant statutes and Ninth Circuit case law governing the substantial evidence standard in Social Security cases. The order is concise but complete in its legal reasoning for adopting the R&R and issuing the final judgment.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MANUEL A. H., Case No. 20-cv-00911-BAS-LL 12 Plaintiff, ORDER: 13 v. (1) APPROVING AND ADOPTING 14 ANDREW SAUL, REPORT AND 15 Defendant. RECOMMENDATION IN ITS ENTIRETY (ECF No. 21); 16 17 (2) GRANTING PLAINTIFF’S MOTION FOR SUMMARY 18 JUDGMENT (ECF No. 18); 19 (3) DENYING DEFENDANT’S 20 CROSS MOTION FOR SUMMARY 21 JUDGMENT (ECF No. 19); AND 22 (4) REMANDING ACTION FOR 23 FURTHER PROCEEDINGS.
26 27 Plaintiff Manuel A. H. commenced this action under the Social Security Act, 42 28 U.S.C. § 405(g), challenging the Social Security Administration’s denial of Plaintiff’s 1 application for Supplemental Security Income (“SSI”) benefits. The Court referred this 2 matter to United States Magistrate Judge Linda Lopez, who issued a Report and 3 Recommendation (“R&R”) on April 15, 2021, recommending that this Court: (1) grant 4 Plaintiff’s Motion for Summary Judgment; (2) deny Defendant’s Cross-Motion for Sumary 5 Judgment; and (3) reverse the decision of the Commissioner and remand the matter for 6 further administrative proceedings. (R&R 27:26–28:2.) The time for filing objections to 7 the R&R expired on April 29, 2021. (Id. 28:7–8.) Both parties are represented by counsel, 8 but to date, neither party has filed any objections. 9 10 I. ANALYSIS 11 The Court reviews de novo those portions of the R&R to which objections are made, 12 28 U.S.C. § 636(b)(1), but where no objections are filed, the district court has no obligation 13 to review the magistrate judge’s report, see United States v. Reyna-Tapia, 328 F.3d 1114, 14 1121 (9th Cir. 2003) (en banc) (“Neither the Constitution nor the statute requires a district 15 judge to review, de novo, findings and recommendations that the parties themselves accept 16 as correct.”); see also Wang v. Masaitis, 416 F.3d 992, 1000 n.13 (9th Cir. 2005) (“Of 17 course, de novo review of a R & R is only required when an objection is made to the 18 R & R.”). 19 In the social-security context, the district court’s jurisdiction is limited to 20 determining whether the Social Security Administration’s denial of benefits is supported 21 by substantial evidence in the administrative record. See 42 U.S.C. § 405(g). A district 22 court may overturn a decision to deny benefits only if it is not supported by substantial 23 evidence or if the decision is based on legal error. See Andrews v. Shalala, 53 F.3d 1035, 24 1039 (9th Cir. 1995); Magallenes v. Bowen, 881 F.2d 747, 750 (9th Cir. 1989). The Ninth 25 Circuit defines substantial evidence as “more than a mere scintilla but less than a 26 preponderance; it is such relevant evidence as a reasonable mind might accept as adequate 27 to support a conclusion.” Andrews, 53 F.3d at 1039. Determinations of credibility, 28 resolution of conflicts in medical testimony, and all other ambiguities are to be resolved by 1 administrative law judge (“ALJ”). See id.; Magallenes, 881 F.2d at 750. The decision 2 the ALJ will be upheld if the evidence is “susceptible to more than one rational 3 interpretation.” Andrews, 53 F.3d at 1040. 4 In this case, no objections have been filed by the deadline for filing objections, which 5 || fell on April 29, 2021. Neither party has requested additional time to do so. Consequently, 6 Court may adopt the R&R on that basis alone. See Reyna-Tapia, 328 F.3d at 1121. 7 || Nonetheless, having conducted a de novo review of the R&R, the Court concludes that 8 || Judge Lopez’s reasoning is sound and correct in recommending that this Court grant 9 || Plaintiff's motion for summary judgment, deny Defendant’s cross-motion for summary 10 ||judgment, and judgment be entered reversing the decision of the Commissioner and 11 |}remanding this matter for further administrative proceedings. Therefore, the Court 12 ||approves and ADOPTS IN ITS ENTIRETY the R&R. See 28 U.S.C. § 636(b)(1). 13 14 ||. CONCLUSION 15 In light of the foregoing, the Court ADOPTS IN ITS ENTIRETY the R&R (ECF 16 21), GRANTS Plaintiff's Motion for Summary Judgment (ECF No. 18), and DENIES 17 || Defendant’s Cross Motion for Summary Judgment (ECF No. 19). The Court REMANDS 18 || this action for further proceedings consistent with this Order. See 42 U.S.C. § 405(g). 19 IT IS SO ORDERED. 20 /\ yy 21 || DATED: May 21, 2021 ( itl A (Lohan 6 22 United States District Judge 23 24 25 26 27 28