Summary
The United States Court of Appeals for the Second Circuit affirmed the District of Vermont’s judgment upholding the Commissioner of Social Security’s denial of Bryan William Husband’s applications for disability insurance benefits and supplemental security income. The court concluded that Husband’s arguments were without merit and adopted the district court’s reasoning, including the treatment of his waived obesity argument.
Topics
Practice areas
Questions Presented
- Whether substantial evidence supported the Commissioner's denial of Husband's applications for disability insurance benefits and supplemental security income.
- Whether the Commissioner applied the correct legal standard in evaluating Husband's disability claims.
- Whether Husband's obesity argument was preserved for judicial review after he failed to raise it in his objection to the magistrate judge's report and recommendation.
Holdings
- The Commissioner's denial of Husband's applications for disability insurance benefits and supplemental security income was supported by substantial evidence and was reached under the correct legal standard.
- Husband waived further judicial review of his obesity argument by failing to raise it in his objection to the magistrate judge's report and recommendation, and the panel declined to review the claim because the waiver did not result in manifest injustice.
Key quotations
“Substantial evidence means more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” (at 2)
Factual background
Husband applied for disability insurance benefits and supplemental security income. The Commissioner denied the applications, and the district court affirmed that decision. On appeal, Husband challenged the denial, including an argument concerning obesity, but the Second Circuit stated that all of his arguments lacked merit and affirmed for substantially the reasons stated in the magistrate judge's report and recommendation.
Procedural history
The magistrate judge issued a report and recommendation dated August 5, 2011, recommending affirmance of the Commissioner's decision. The district court adopted the report and recommendation in its entirety and entered judgment affirming the Commissioner. Husband appealed, and the Second Circuit affirmed by summary order without oral argument.